Remote Year Privacy Policy

Version 1.3
Effective Date: May 25, 2018

Remote Year, Inc. its subsidiaries and other entities within its corporate group structure (collectively, “we”, “us”, “our” or “Remote Year”) respect the privacy of our users and we are committed to informing you about how we collect, use, and share Personal Information about you which is submitted by you or on your behalf. This Privacy Policy describes our practices with respect to the information we collect from or about our users in connection with the Remote Year website, portal, and/or mobile application (collectively, the “Remote Year Platform”) and Services (as defined in the Participant Terms and Conditions). This Privacy Policy applies to persons anywhere in the world who use the Remote Year Platform or Services. For clarity, Services includes the Remote Year Platform..

Please read this Privacy Policy carefully to understand how we will treat your Personal Information (as defined below) and by continuing to browse the website or purchase or use any of our services you are deemed to have accepted the terms of this Privacy Policy.

In addition, we recommend that you review our Privacy Policy periodically, because we may revise it at any time. We are constantly trying to improve Remote Year, so this Privacy Policy may need to change. We reserve the right to change the Privacy Policy at any time, but if make material changes, we will bring them to your attention by placing a notice on remoteyear.com, by sending you an email, and/or by some other means. The “Effective Date” at the top of this page indicates when our Privacy Policy was last revised.  Each time you use the Remote Year Platform or provide us with information, you accept the practices described in this Privacy Policy as applicable at that time.

Personal Information and Other Information Processed by Remote Year

Remote Year processes both Personal Information and Other Information about its users through their use of and in connection with the Services.  For purposes of this Privacy Policy (i) “Personal Information” is information relating to a person who is identified in that data or who is, together with other data, identifiable; and (ii) “Other Information” is any additional information that Remote Year collects about our users that is not Personal Information.

Personal Information you provide: you may give us your Personal Information directly, for example, when you fill in forms on the Remote Year Platform, correspond with us (for example, without limitation, by email, phone, skype, zoom, or chat), register to use the Remote Year Platform, access our mobile applications or services, create an account with us or otherwise use the Remote Year Platform. The Personal Information you give us directly will usually include your name, address, email address, social media details, contact details, emergency contact details, billing information, photos, videos, voice recordings and information about your family and friends. It also includes the information provided in your application forms such as employment history and current employment details, income details, travel plans, personal and professional goals, languages, nationality and residency, passport details, background check and identity check details (including details of any criminal offences), health data, details of personal interests, lifestyle details, sexual orientation, accommodation preferences and insurance details. All information and content submitted by you to the Remote Year Platform may be retained by us indefinitely, even after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy.

We may use your contact information to send you information about the Services. You may unsubscribe from some of these messages by using the unsubscribe link provided in each email, although, we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Personal Information we collect: we may combine Personal Information collected through the Remote Year Platform with Other Information that we or third parties collect about you in other contexts—such as our communications with you via email, phone or otherwise or your customer service records and travel details.  Additionally, if you register for or access the Remote Year Platform using a third party service, we may receive Personal Information that you allow such third party service to share with us.  You acknowledge that this information may be personal to you, and by creating an account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous.

We will treat all such information, to the extent combined with Personal Information, as Personal Information and protect it in accordance with this Privacy Policy.

Other Information we collect: each time you log onto your account or use the Remote Year Platform, we may, in some cases automatically, collect the following information:

How We Use Your Personal Information

Remote Year may use the information that we collect from you:

Remote Year may link Other Information with Personal Information. In those circumstances, we will treat the combined information as Personal Information.

How We Share Information with Third Parties

Subject to applicable law, we may share your Personal Information and Other Information:

Cookies

Cookies are small data text files that save on your computer or mobile device when you access a website. Your browser stores cookies in a manner associated with each website you visit. Cookies enable websites to remember your actions and preferences (such as login, language and other display preferences) over a period of time. To make the Remote Year Platform work properly, we sometimes use cookies. Remote Year uses cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use our services and website through the Internet, to analyze trends, and to learn about our user base.

We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an account.  We may also supplement the information we collect from you with information received from third parties in order to enhance our services, or to offer you information that may be of interest to you.

Most browsers automatically accept cookies, and have an option for turning off the cookie feature, which will prevent the browser from accepting new cookies, as well as (depending on the sophistication of the browser software) allowing the user to decide on the acceptance of each new cookie in a variety of ways. If you choose to decline cookies, some parts of the Remote Year Platform may not work as intended or may not work at all. For more details, see aboutcookies.org.

Please reference the chart below to learn more about the kinds of cookies we use and for what purpose.

We use cookies to help us improve, promote, and protect our services. By continuing to use the Remote Year Platform, you agree to our cookie policy. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Where We Store Your Information

The information that we collect from you may be transferred to, and stored at, a destination (a “third country”) outside the country or region in which you are resident or use the Remote Year Platform, including in the United States of America where data protection laws are not deemed to be as adequate as other regions (e.g. Europe). The data protection laws in these third country countries may be less adequate compared to your country of residence. By using the Remote Year Platform, you agree to this transfer, storing or processing of your laws in such third countries.

Our Security Precautions

Remote Year uses commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification or deletion but no security program can be guaranteed to be 100% secure. As a result, Remote Year cannot guarantee the security of any information obtained or processed by Remote Year or its service providers, and you use the Remote Year Platform at your own risk. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user places an order to maintain the safety of your Personal Information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

We will take commercially reasonable steps to ensure that your data is treated in accordance with this Privacy Policy.

Additionally, you are responsible for preventing unauthorized access to your account and Personal Information by protecting your account credentials and limiting access to your devices.

Your Rights

You may, under applicable law, have the right to ask us not to process your Personal Information for marketing purposes.  If you do not wish to receive marketing communications from Remote Year, please follow the opt-out instructions contained in each such communication or any time by contacting us at media@remoteyear.com.  Please note that you may not be able to opt-out of certain non-marketing communications about your account or communications that are reasonably necessary to provide services to you, and that opting-out of receiving text messages or other communications, as applicable, may impact your use of the Remote Year Platform or may limit Remote Year’s ability to provide services to you.

Please note that it may take up to 30 days for your withdrawal to be reflected in our systems following confirmation of your request to opt-out.  Therefore, you may still receive certain communications during this period.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Remote Year, Inc. 3500 South DuPont Highway, Dover, DE 19901

Opting out of Interest Based Advertising

We use Google and Facebook services to advertise to you. Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We have implemented demographics and Interests Reporting.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties and to opt out of receiving certain cookies and certain trackers, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices or http://youronlinechoices.eu.

Do Not Track

Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites.  The Remote Year Platform does not currently support the Do Not Track options offered by most major browsers. For more information about DNT signals, visit  http://allaboutdnt.com.

Accessing & Editing Your Information

Remote Year provides you with the ability to view, update, access, edit and correct your Personal Information by contacting our Onboarding team at welcome@remoteyear.com (if your program has not yet launched), by contacting your program leaders (if your program has launched), or by contacting citizens@remoteyear.com (if you’re a Remote Year Citizen). Personal Information transmitted through boards, chats, polls or any other means may remain in our databases, except to the extent prohibited under applicable law.

You may have additional rights under applicable law to access information we hold or share about you but any access request may be subject to a reasonable fee, to the extent permissible under applicable law, to meet our costs in providing you with details of such information.

Children's Privacy

The Services are designed for adults only and are not available to children (i.e. persons who are under 18 years of age) or users who have had their user account temporarily or permanently deactivated. By becoming a user, you represent and warrant that you are an adult and that you have the right, authority and capacity to enter into and abide by the terms and conditions of this Privacy Policy. We reserve the right to verify your information and can exercise our absolute discretion not to provide any Services to you if we are not satisfied that you are an adult. If a child has provided us with Personal Information, a parent or legal guardian of that child may contact us as described below. Upon confirmation, we will then make reasonable efforts to delete the child’s Personal Information from our applicable database.

Contact

Questions, comments, and requests regarding this Privacy Policy should be addressed to privacy@remoteyear.com.

NOTICE FOR RESIDENTS OF THE EU, UK, LICHTENSTEIN, NORWAY, OR ICELAND

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Remote Year will be the controller of your Personal Data processed in connection with the Services.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, Remote Year’s Privacy Policy. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@remoteyear.com.

What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

Information we receive from third party sources:  Some third parties such as your employer (if they are a Remote Year enterprise partner), our Payment Processors, or our advertising partners provide us with Personal Data about you, such as the following:

Information we automatically collect when you use our Services:  Some Personal Data is automatically collected when you use our Services, such as the following:

How Do We Use Your Personal Data?  We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?  We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

Personal Data of Children:  As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from someone under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at privacy@remoteyear.com.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@remoteyear.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us at privacy@remoteyear.com

REMOTE YEAR, INC. is registered with the State of Florida as a Seller of Travel. Registration No. ST41031