PRIVACY POLICY
 
Introduction
RallyPoint is a social network and online platform specifically designed to connect current or former members of the United States military services, to allow them to communicate, exchange stories and information of interest.  RallyPoint connects members and visitors with employers and brands in a personalized and relevant way, by allowing them to grow a personal network and present relevant and personalized promotions or employment opportunities.  With RallyPoint, you can build out your professional network, connect with other members of the military and veterans in a safe environment, and explore career opportunities both within the military (PCS opportunities) and in the private sector.
 
This privacy policy applies to RallyPoint.com and the RallyPoint mobile application, and all other RallyPoint consumer-facing products and services. Any information that you upload or sync with RallyPoint is covered by the User Agreement and this Privacy Policy. You can remove your information at your convenience using the features RallyPoint makes available. You can remove your address book and any other synced information at any time by requesting this.
 
BY ACCESSING OR USING THE WEBSITE OR THE APP OR ANY OTHER RALLYPOINT PRODUCT OR SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS.  IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE WEBSITE OR THE APP  This policy applies to registered members and visitors alike. 

What Information Do We Collect From or About Consumers or their Devices?
 
Personal Information:  In this policy, Personal Information is information that can be used to identify a natural person.  We collect the following Personal Information:  
  • when you sign up (whether on the App or the Website), and  create or make changes to a RallyPoint profile, we collect the personal information you disclose on the account registration form and your profile, including your email address, password, contact information, first name, last name, gender, birthday, branch of service, rank, military specialty, current unit and duty station, professional experience or objectives, educational background, and any other information you provide at registration or add to your profile;
  • if you communicate with us by email, we will collect your email address;
  • when you access our Website or use the App, our servers will automatically recognize your IP address, and device IDs;
  • if you submit Content, you may, at your option, include information (such as your name or photograph) in the Content that can be used to identify you.  
  • if you contact us for customer support, we may collect your contact information, and access your data associated with your account, including Content.  
All of this information is referred to in this Policy as “Personal Information”.
 
Logging in via other Social Networks and Syncing Your Data
  • If you login to the RallyPoint using your account information for a Social Network Site, we access and collect information about your use of the Social Network Site and information you provide to such Social Network Site.  To the extent you and the Social Network Site allow, we may access all of your information that is publicly available to other users of the Social Network Site and all information you have provided to the Social Network Site, such as login e-mail and other contact information, network statistics and updates regarding your Social Network Site account. You consent to such access and our collection, storage and use of this information in accordance with this Privacy Policy.  
  • The App uses email addresses and profile ID’s to identify other members on RallyPoint with whom you may be connected on other Social Network Sites but have not connected with yet on RallyPoint. 
  • If you use our contact importer feature to automatically sync your contacts from your devices, other online accounts, or other social networks to RallyPoint, we will collect and store that information.  (You can remove your address book or other synced information whenever you would like.)  If you utilize RallyPoint features that sync external email and calendar services, RallyPoint will access your email and calendar accounts, as well as  access and y store some of your email header and calendar history information in order to match it to RallyPoint and other public social media profiles. These features may also temporarily cache message content for performance reasons, in a way that is unreadable by RallyPoint and its service providers.
‚ÄčAutomatically Collected Information 
  • Mobile Device Information.  RallyPoint will collect and pass to third parties advertising-specific device identifiers unless you have opted-out of ad tracking for the device.  Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device.  
  • Web Tracking Information: We, and our third party service providers, may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Website efficiently and to collect data related to usage of the Website and to web and email marketing conducted by us or on our behalf.  Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visit and what links you clicked on, and whether you opened email communications we send to you.  In order to collect Web Tracking Information and to make your use of the Website more efficient, we may store cookies on your computer.  In addition, the third party ad networks (“Ad Networks”) that we use to display advertising to you may also store their own cookies on your computer.  We may also use web tracking technologies that are placed in web pages on the Website or in email communications to collect information about actions that users take when they interact with the Website or such email communications, and Ad Networks and RallyPoint’s Contractors (as hereinafter defined) may also do so.  We do not correlate Web Tracking Information to individual user Personal Information.  Some Web Tracking Information may include data, such as IP address data and general segment information (e.g., your unit, career field, or information about your professional or educational background, that is unique to you.  You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Website, but this may affect the performance of the Website.
How Do We Use the Information We Collect?
We use the information we collect from or about you and your devices for a variety of purposes:
  • Provide you with customized RallyPoint social networking and communication services via our Website or the App
  • Communicate with you about your RallyPoint account or profile, your transactions with us and send you information about features on our Website and the App changes to our policies
  • To allow you to grow, manage, and leverage your RallyPoint network:
    • By using the RallyPoint contacts importer (or other similar mechanisms provided by RallyPoint) to upload individual contacts or your entire address book into RallyPoint. 
    • By identifying your contacts already on RallyPoint; informing your contacts that you are building your RallyPoint network; providing a template to send invitations to your contacts that have not registered with RallyPoint; and suggesting people you may know but who may not be in your RallyPoint contacts. 
    • RallyPoint may also use this information to show you and other members that you share the same uploaded contacts who may or may not be members.
  • Consistent with local law and choices and controls that may be available to you we may use information collected from you, or from devices associated with you, to: 
    • Connect you with potential military or veterans organizations which we have vetted and which we believe to have the best interest of the member in mind
    • Connect you with employment opportunities
    • Show you offers and promotions for our products and services or third-party products and services
    • Personalize content and experiences
    • Provide you with advertising based on your activity on our sites and applications and on third-party sites and applications. To learn more about how we use your information for personalization and tracking, please see "Automatically Collected Information" below.
  • Optimize or improve our products, services and operations
  • Detect, investigate and prevent activities that may violate our policies or be illegal
Please note that when you send an invitation to connect to another individual (a “connection”), that person may have access to your email address or, for SMS invitations, mobile number because it may be displayed in the invitation. RallyPoint may also remind you of pending invitations. Your RallyPoint connections may also have access to your email address.
 
Aggregate Information and Analysis:  We will also use information we collect from or about you and your devices to create aggregated data for individual or summary analytical purposes.  This statistical information does not contain any Personal Information and is used to understand our members and to better serve our market.
 
Tracking Information:  We use Web Tracking Information to administer the Website and the App and to understand how well our services are working, to store your user preferences and customize the RallyPoint content you see, and to develop aggregate, statistical information on usage of the Websites.  This allows us to determine which features visitors like best to help us improve our Website, to personalize your user experience, and to measure overall effectiveness.
 
Legal Exception:  Notwithstanding the above, we may in any event use Personal Information and other information collected through the Website to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.
 
Push Notifications:  If you download and install the App, we will send you administrative and promotional push notifications, provided that you opt in to such notifications through the App settings.  
 
Email Communications/Your Choices:  If you create an account and provide your email address, we will send you administrative and promotional emails.  If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings as described below.  All users receive administrative emails, and so you cannot opt out of them while you remain an account holder.
 
What Information Do We Disclose to Third Parties?
We disclose the Personal Information we collect from or about you as follows:
  • within the RallyPoint services, to your current employer and/or potential employers and recruiters who are looking to hire personnel with your skill sets;
  • within RallyPoint, to companies, or organizations looking to provide services based on your unique accomplishments or background;
  • to third party service providers or contractors engaged to provide services on our behalf (“Contractors”), such as performing marketing services, analyzing data and usage of the App, operating the App or providing support and maintenance services for the App, or providing customer service.  We use reasonable efforts to enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us.
  • to partner organizations with whom we think our military members have a strong affinity, to facilitate the delivery of more relevant ads and email marketing (described below under "Advertising-related disclosures of information and Opt-Out instructions"); 
  • to carry out your instructions, and 
  • when we have your consent to share the information.
Aggregate Information:  We may disclose anonymous, aggregated information to third parties such as current and potential business partners, advertisers, and funding sources, in order to describe our business and operations.
 
Advertising-related disclosures of information and Opt-Out instructions.  RallyPoint is an ad-supported service.  
  • We work with partner organizations with whom we think our military members have a strong affinity, to facilitate the delivery of more relevant ads and email marketing.  We do this by working with third party data brokers such as LiveRamp, who use cookies or Mobile advertising IDs to connect our data with our partner’s data, so that they can better target promotional or advertising communications to our mutual members.
  • We may share your email address or other personally identifying information you provide to us with LiveRamp, our data partner. LiveRamp deidentifies this information with a hashing algorithm, and matches this information with other information about you it has collected from other sources in LiveRamp’s network , including cookies or Advertising IDs placed on your devices. When we do this, we contractually prohibit LiveRamp from re-identifying our members through their email address or other Personal Information . The deidentified information is used to deliver and measure tailored and relevant content, advertising, services, and experiences at RallyPoint, and also as you interact with other applications or websites. We also use this information to develop new services. Learn more about LiveRamp here and LiveRamp’s Privacy Policy here.  Opt out of LiveRamp sharing and uses generally here.
  • We allow other companies to advertise on RallyPoint, and allow them to use cookies and similar technologies such as pixels, tags, beacons and other technologies to collect information about you.  Similarly, we may receive information about you as a result of ads we place on other websites and apps through cookies and similar technologies such as pixels, tags, beacons and other technologies.
  • When we collect information about you through third-party advertising networks or other advertising, we use the information for the purposes described in this Privacy Policy.  The information practices of third-party advertising networks and their participating companies and the information practices of our other advertisers are not covered by this Privacy Policy. 
RallyPoint only shares its data for ad retargeting purposes with  members of the Digital Advertising Alliance (DAA) who adhere to the DAA Principles for Online Behavioral Advertising and Multi-Site Data, as well as related guidance. The DAA administers an industry-wide cookie opt-out mechanism that can be found here and its mobile device ID opt out available through its AppChoices app.  Keep in mind that opting out through the DAA or other channels does not disable advertisements altogether. Instead, opting out means that we or our authorized data partners will no longer facilitate targeted advertising to your browser, mobile device, or email address. In other words, you will still see advertisements and receive email marketing, but they will be less relevant to you.  If you create a new email address, reset the mobile advertising ID on your device, or use a new browser, you will need to apply the appropriate opt out to that new email address, new device ID, and/or new browser as opt-outs are not necessarily transferred between email addresses, browsers, or devices.
 
For another tool to opt out of tracking on 3rd party networks , click here to visit the Network Advertising Initiative site to set preferences and opt out of third party targeting programs.
 
Third-Party Analytics.  We use third-party analytics services, such as Google Analytics, to evaluate the performance of various features of our Website and App and also to evaluate the overall performance of our Website and App.  We also use such services to understand whether and how specific users or users meeting a certain profile are taking advantage of certain features of our Website and App and/or making use of our Website and App generally.  For more information about web analytics, including information on setting preferences for or opting out of certain data collection, please visit Google Analytics.  If you choose to opt-out, some of the features of the Website and App may not be fully functional for you.
 
We do not share information that personally identifies you (personally identifiable information is information like name or email address that can by itself be used to contact you or identifies who you are) with advertising, measurement or analytics partners unless you give us permission. We may provide these partners with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you. 
 
Network Operators: Use of the RallyPoint App may involve use of the services of third party telecommunications carriers.  Such carriers are not our contractors, and any information that a carrier collects in connection with your use of the App is not “Personal Information” and is not subject to this Privacy Policy.  We are not responsible for the acts or omissions of telecommunications carriers.
Additional Disclosures:  We reserve the right to disclose any information we collect in connection with the App, including Personal Information, (a) to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.
 
RallyPoint Profile Privacy Settings:  You may choose which RallyPoint users can view your profile through your RallyPoint privacy settings.  You may choose to make your profile private so that it can only be seen by you.  If you set your profile as private, other RallyPoint users may not view your profile but your profile will be available to potential employers with access to RallyPoint.
 
Search: You can search for members, employment opportunities, information about companies, and community content on our Services. You can also find employment opportunities and information about companies. We use Personal Information from our Services to inform and refine our search service.
 
Privacy Settings/E-Mail Preferences/Data Retention
If you would like to close your RallyPoint account or opt-out of email updates, please visit your RallyPoint settings page where you can control all your privacy settings or close your account. If you close your account, your data will no longer be displayed on the RallyPoint network and other RallyPoint members will not be able to find you.  Your removal will not remove records of past transactions or delete information stored in our data backups and archives.  Data on past transactions and data stored in backups and archives will be maintained and/or deleted in the ordinary course of RallyPoint’s business.
We retain the Personal Information you provide while your account is in existence or as needed to provide you services. We may retain your Personal Information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Service. We may retain Personal Information, for a limited period of time, if requested by law enforcement. 
 
Access and Updating of Information
You may review or amend your profile, email address, or contact details at any time by using your settings panel in your account online.
 
General
Security:  We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law.  However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur.  Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.
Links: The RallyPoint website may contain links to other websites. RallyPoint is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our website and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by the Website.
Amendments: RallyPoint may modify or amend this policy from time to time. If we make any material changes, as determined by RallyPoint, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes, which will be available for review by you at the Website.  Notwithstanding any modifications we may make, any Personal Information collected by RallyPoint from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.
You Must be 18 Years or Older to Participate in RallyPoint:  RallyPoint does not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of the Website is directed at persons under 18.  If you are under 18 years of age, then please do not use RallyPoint. 
 
Website Visitors from outside the United States:  RallyPoint and its servers are located in the United States and are subject to the applicable state and federal laws of the United States.  If you choose to access or use the Website, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.
 
Effective Date of this policy: August 16, 2017
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