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Privacy Policy

TWO RIVERS MARKETING PRIVACY POLICY

At Two Rivers Marketing, we want you to know how we collect, use, share, and protect information about you. We are committed to ensuring that your privacy is protected, and we have created this privacy policy to inform you of how we handle private information.

For your convenience, Two Rivers has made it easy to navigate our privacy policy. Simply choose your policy below to skip to that section.

  1. Definitions
  2. Types of Data We Collect
  3. How Your Information is Collected
  4. How We Use Your Data
  5. Who We Share Your Data With
  6. Where We Send Your Data
  7. How Long We Retain Your Data
  8. How Your Data is Protected
  9. Managing Your Data
  10. California Consumer Privacy Act (CCPA) - California Residents Only
  11. Residents of Other States
  12. Canadian Residents: Compliance with CASL and PIPEDA
  13. General Data Protection Regulation (GDPR) - European Union Residents Only
  14. Non-Discrimination
  15. Accessibility
  16. Agency Communications
  17. Minors
  18. Policy Updates
  19. Contact 2RM

    DEFINITIONS

    Consumer: A consumer is a natural person who is a resident of a state with a Data Privacy Law, living in a state with a Data Privacy Law for other than a temporary or transitory purpose, or an individual domiciled in a state with a Data Privacy Law.

    Data Privacy Laws: All applicable federal, state, and foreign laws, rules, regulations, and guidance (and any implementing legislation or regulations thereunder as amended) pertaining to consumer data privacy.

    Personal Information (“PI”): Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include:

    • Publicly available information lawfully made available from government records.

    • Deidentified or aggregated consumer information that cannot be reasonably linked to an individual.

    • Information excluded from Data Privacy Laws, like:

      • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health (HITECH) Act, health or medical information covered by applicable state privacy and/or confidential laws or regulations, or clinical trial data; and

      • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), and the Gramm-Leach-Bliley Act (“GLBA”) or applicable state financial confidentiality laws and regulations.

    Note: If certain types of information are excluded from Data Privacy Laws, this policy will not apply to such excluded data.

    Sensitive Personal Information (“SPI”): is a subset of PI which includes, but may not be limited to:

    • Government identification numbers, such as social security numbers, driver’s license numbers, state identification numbers, or passport numbers;

    • Account login information;

    • Financial account, credit, or debit card numbers, combined with a password, PIN, or other required security or access codes;

    • Precise geolocation;

    • Racial or ethnic origin, religious or philosophical beliefs, or union membership;

    • Content of postal mail, email, or text messages, unless VGM is the intended recipient of those communications;

    • Biometric data that uniquely identifies an individual or information concerning an individual’s health, sex life, or sexual orientation; and

    • Genetic data

    TYPES OF DATA WE COLLECT

    Should we ask you to provide certain information by which you can be identified when using this website, it will only be used in accordance with this privacy policy. The information collected may vary by use case, and may include but is not limited to:

    Category

    Example

    Collected?

    A. Identifiers.

    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver's license number, passport number, mobile device information (e.g., device model, operating system version, device date and time, unique device identifiers, mobile network information), or other similar identifiers.

    YES

    B. Personal Information categories listed in Data Privacy Laws.

    Information that is protected against security breaches, such as name, signature, social security number, physical characteristics or description, address, telephone or mobile device number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

    Some PI included in this category may overlap with other categories and may not be subject to all the rights under Data Privacy Laws

    YES

    C. Protected classification characteristics under state or federal law.

    Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, and genetic information (including familial genetic information).

    YES

    D. Commercial information.

    Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.

    Media information (e.g., advertising engagement in social, digital, and broadcast media).

    YES

    E. Biometric information.

    Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    NO

    F. Internet or other similar network activity.

    Use of a Site, including browsing history, search terms and history, and information on a consumer's interaction with a Site (i.e., pages visited), application, or advertisement.

    YES

    G. Geolocation data.

    Physical location or movements.

    YES

    H. Sensory data.

    Audio, electronic, visual, thermal, olfactory, or similar information.

    NO

    I. Professional or employment-related information.

    Current or past job history or performance evaluations.

    YES

    J. Non-public education information (per the Family Educational Rights and Privacy Act [20 U.S.C. Section 1232g, 34 C.F.R. Part 99]).

    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    NO

    K. Inferences drawn from other PI.

    Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    NO

    L. Sensitive PI

    As defined above.

    YES


    We generally do not collect additional categories of PI or use the PI we collected for significantly different or meaningfully unrelated purposes without providing notice to you.

      HOW YOUR INFORMATION IS COLLECTED

      When interacting with 2RM Marketing, your personal information may be collected in a variety of ways, including voluntarily provided, automated sources, third-party sources (including social media), and other online resources. The information below has been created to help you better understand how we gather your information. You can better understand your data rights in the "opting-out of data use or withdrawing consent" portion of the policy.

      INFORMATION YOU PROVIDE

      Contact forms
      We may collect information from you when you subscribe to our newsletter or fill out our contact form. We may also collect personal information, like employment and employment history submitted to us in connection with job applications through ADP. This information may include your name, email address, postal address, telephone number, and other information, including your resume and associated information.

      Cookies
      Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

      You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. To learn how you may be able to reduce the number of cookies you receive from us or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser.

      AUTOMATED INFORMATION

      Analytics
      In addition, we may automatically collect information, such as IP host address, web pages viewed, browser type, browsing path, and other data. We also utilize technologies on this site to collect usage information, including device identifiers and cross-device tracking, which may include but are not limited to analytics software, plugins, and pixels. Similarly, we use analytics tools to help us track and analyze usage of our site, using cookies, pixels, plugins, and other tracking technologies.

      Social Media
      If you interact with 2RM Marketing or any third parties by and through any forums or interactive areas of our site or any social media platforms, you should be aware that the personal information that you submit by and through such venues can be read, collected, and/or used by other users of these forums (depending on your privacy settings) and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire. We are not responsible for the personal information that you choose to submit in these forums. In addition, we are not responsible for and do not control third-party social media platforms’ privacy or security practices. We encourage you to review the privacy policies and settings of the third parties with whom you interact to help you understand their privacy practices.

      You may also adjust your advertising preferences on various social media websites. Read the “Managing your data” portion of this privacy policy.

      OTHER SOURCES

      Embedded Content From Other Websites
      Articles on this site may include embedded content (e.g., videos, images, articles). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

      These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

      Links to Third-Party Websites
      Occasionally, at our discretion, we may link to other websites of interests or third-party products or services. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. You should exercise caution and review the privacy statement applicable to the website in question.

      HOW WE USE YOUR DATA

      At 2RM, we are always looking for ways to better serve our clients and communities. To that end, we may use your data for the following:

      • To fulfill or meet the reason for which the information is provided. For example, to follow up on your inquiries or marketing needs through the contact request form.

      • To provide you with information, products, or services that you request from us, including answering your queries, and to notify winners of any promotions.

      • Contracting with service providers to perform services on our behalf, including but not limited to maintaining or servicing clients, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf.

      • Otherwise enabling or effecting, directly or indirectly, a business or commercial transaction.

      • To improve our website.

      • To monitor and analyze trends, usage, and activities in connection with our website.

      • To personalize the site and show you content that's relevant to you.

      • Testing, research, analysis, and product and service development.

      • Providing you with email alerts, event registrations and other notices concerning 2RM’s services, or news that may be of interest to you.

      • Facilitating the connection of third-party services or applications, such as social media.

      • As necessary or appropriate, to protect the rights, property, or safety of us, our employees, our customers, or others.

      • Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.

      • Facilitating transactions and payments.

      • Deidentifying and aggregating information collected through our services and using it for any lawful purpose.

      • Responding to trust and safety issues that may arise as necessary or appropriate to protect the rights, property, or safety of 2RM, our employees, our customers, or others.

      • Carrying out our obligations and enforcing our rights arising from any contracts or other terms entered into between you and 2RM, including billing, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

      • Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

      • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

      • Debugging to identify and repair errors that impair existing intended functionality.

      • Short-term, transient use.

      • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

      • For other purposes with your consent for which we provide specific notice at the time the information is collected.

      • For automated decision-making, including email segmentation and message personalization.

      • For any other purpose with your consent.

        WHO WE SHARE YOUR DATA WITH

        If you choose to provide your information, we will only use your personal information for the purpose it was given to us. We will never sell, trade, or rent your personal information to any third party without your consent.

        California law requires that we provide transparency about personal information we “sell,” which for the purposes of the CCPA broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. We do not, and will not, sell identifying information, such as your name, email address, phone number, or postal address.

        WHERE WE SEND YOUR DATA

        Aggregate information may be shared with any number of parties, provided that such information does not specifically identify any individuals.

        HOW LONG WE RETAIN YOUR DATA

        2RM implements and maintains reasonable restrictions on the retention of personal information collected through this website and generally disposes of such personal information once it is no longer necessary for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal information for legitimate business purposes and as necessary to comply with applicable law for up to 12 months. In addition, we may continue to store anonymous, aggregated, or anonymized information for any legitimate business use described in this privacy policy.

        HOW YOUR DATA IS PROTECTED

        We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we implement a variety of security measures to maintain the safety of your personal information when you enter or submit your personal information, including but not limited to:

        • Using an SSL certificate on tworiversmarketing.com

        • Restricting login access to our website to employees and our website partner(s)

        • Regularly applying platform updates to ensure site security

        • Using a site application firewall that’s updated daily to protect our site from malware, ransomware, and viruses that hackers try to push into database websites

        However, due to the inherently open nature of the internet, we cannot guarantee that communication between you and 2RM or information stored on tworiversmarketing.com or our servers will be free from unauthorized access by third parties, such as hackers, and your use of the website demonstrates your assumption of this risk. We have put in place physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information to perform their duties are authorized to have access to your personal information.

        MANAGING YOUR DATA

        We strive to provide you with choices regarding the personal information you provide to us. There are various mechanisms to provide you with control over your information, including those listed in this section.

        Cookies
        You can set your browser to refuse all or some browser cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies (including those of third-party vendors) when you direct your browser to the Site. To review or manage the cookies being collected, see our cookie consent list.

        Email Communications
        To opt out of receiving our newsletter and/or other promotional email communications from us, you can follow the instructions at the end of the applicable email message or contact us via mail.

        Social Media
        You may also adjust your advertising preferences on various social media websites by adjusting your settings on the platform (for example, you may adjust the types of Facebook ads you receive).

        Other Tracking Technologies
        You may remove certain tracking technologies and opt out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). Please note that these opt-out tools are device- and browser-specific, so you must repeat the opt-out from each of your browsers and devices.

        OPTING OUT OF DATA USE OR WITHDRAWING CONSENT

        As described above, we collect personal data about you when you voluntarily provide it to us, and we collect other data about you and your use of the website automatically when you interact with us. If you do not want us to use your collected data as described above or if you wish to withdraw your consent to permit us to process your personal data, please complete our data request form.

        If you no longer wish to receive email communications from 2RM, you can opt out of receiving such messages in the future by following the unsubscribe instructions in the email or contacting us.

        With respect to the website’s use of cookies, pixels, tags, and other similar technologies, by adjusting settings on your browser you may elect not to allow cookies to be placed, and thus opt out of certain features of the website and the website’s automatic collection of certain data about you.

        CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

        Personal Information Purposes
        If you are a California resident, the information below also applies to you. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act (“CCPA”).

        Your Rights
        If you are a California resident, you have the right to request more information about the categories and specific pieces of personal information we have collected, sold, and disclosed for a business purpose in the last 12 months, deletion of your personal information, and to opt out of sales of your personal information, if applicable. You may make these requests by sending an email request to 2RM at the email address provided at the end of this policy, in our cookie consent banner, or by clicking Do Not Sell My Information. Once we receive your request, we will verify it by asking you to provide contact information and information related to your recent interactions with us. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

        RESIDENTS OF OTHER STATES

        As privacy laws continue to be adopted in other states, residents of those states may be accorded certain rights. These rights can vary from one state to another, and may include rights of access, correction, or deletion of personal information, rights to opt out of targeted advertising or sale of personal information, rights to appeal, protections against discrimination, and other rights. You may exercise your rights in the same manner as described in the CCPA “Your Rights” paragraph immediately above.

        CANADIAN RESIDENTS: COMPLIANCE WITH CASL AND PIPEDA

        2RM is committed to protecting the privacy of individuals and complying with applicable Canadian data protection laws.

        CASL sets rules for the sending of commercial electronic messages (CEMs), the installation of computer programs, and the alteration of transmission data. Specifically:

        • We will only send CEMs to individuals who have provided their explicit or implied consent, except as otherwise permitted by CASL

        • Our CEMs will include clear identification of the sender, a valid physical address, and a working unsubscribe mechanism that allows you to withdraw your consent at any time

        • We will keep records of your consent and any CEMs we send for compliance purposes

        Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), you have certain rights with respect to your personal information, including:

        • The right to access your personal information

        • The right to correct or update your personal information

        • The right to request that we delete your personal information

        • The right to withdraw your consent to the collection, use, and disclosure of your personal information

        • The right to object to the processing of your personal information for certain purposes

        • The right to restrict the processing of your personal information

        • The right to lodge a complaint with the Office of the Privacy Commissioner of Canada

        If you believe that the personal information we have about you is inaccurate or incomplete, you can access, correct, or update your personal information by contacting us using our data request form. We will respond to your request within 30 days.

        We will only send you marketing and promotional materials if you have provided us with your express consent. You can withdraw your consent at any time by clicking on the "unsubscribe" link at the bottom of any marketing email you receive from us.

        GENERAL DATA PRIVACY PROTECTION REGULATION (GDPR)

        If you are accessing the 2RM website from the European Economic Area, which includes the European Union member states, Iceland, Liechtenstein, and Norway, you have the following rights under the General Data Protection Regulation (GDPR).

        • Right to be informed about the collection and use of your personal data

        • Right to access your personal data

        • Right to have any inaccurate personal data corrected

        • Right to have your personal data erased

        • Right to restrict use of your personal data

        • Right to personal data portability

        • Right to object to the processing of your personal data

        The data that you provide to us or we obtain as a result of your use of this Site will be collected, stored, and processed in a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection laws, including the United States. We may transfer your personal data outside the EEA in order to store it and enable us to provide advertising, products, or services to you.

        Where your personal data is transferred outside the EEA, including the U.S., we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this privacy policy. By using this Site and/or providing us with your personal data, you (a) consent to the transfer and/or processing of any personal data outside the EEA, including to the U.S., (b) acknowledge that U.S. law may not be equivalent to the data protection laws of your location, and (c) understand that we will collect, transfer, store, process, and/or deal with your personal data in accordance with this privacy policy.

        If you wish to exercise any of these rights under the GDPR, please email your request to us. We will respond to any requests without undue delay and no later than one month after receipt of your request.

        NON-DISCRIMINATION

        2RM will not discriminate against you because you exercise your rights. For example, 2RM will not deny you services or charge you a different price or rate for goods or services if you make an access, deletion, or do not sell request.

        ACCESSIBILITY

        Two Rivers is committed to providing websites that are accessible to the widest possible audience, regardless of technology or ability. Two Rivers Marketing endeavors to comply with best practices and standards.

        Content on TwoRiversMarketing.com will be compliant with the standards defined by Section 508 of the U.S. Rehabilitation Act and Level AA of the W3C Website Content Accessibility Guidelines (WCAG), version 2.1. Additionally, Two Rivers Marketing is committed to testing the website to make sure that existing content on the site is accessible to all visitors.

        If you would like additional assistance or if you experience an accessibility barrier on our website, please contact Two Rivers Marketing.

        AGENCY COMMUNICATIONS

        Any communication or material you transmit to us by electronic mail or otherwise, including any data, questions, comments, suggestions, or the like, is and will be treated as non-confidential and non-proprietary. Except to the extent expressly covered by our privacy policy, anything you transmit or post may be used by us for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast, posting, and/or ranking.

        Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us without compensation and for any purpose whatsoever, including but not limited to developing, manufacturing, and marketing products and services using such information.

        MINORS

        The website is intended for use only by persons who are at least 18 years of age and who are fully able and competent to enter into and be legally bound by this privacy policy. Accordingly, we do not intend to collect personal information from anyone whom we know to be under 13 years of age.

        POLICY UPDATES

        We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. If we decide to change our privacy policy, we will post those changes on this page and/or update the privacy policy modification date below. Your continued use of the website following the posting of any changes to this policy means you accept such changes.

        CONTACT TWO RIVERS MARKETING

        If there are any questions regarding this privacy policy or your personal data, please contact us at:

        2RM
        106 E. 6th Street
        Des Moines, IA 50309
        Phone: (515) 557-2000
        privacy@2rm.com

        Policy Last Modified: 7/23/2024