Our Commitment to Privacy
Your privacy is important to Rubicon Carbon Services, LLC and its affiliates (together, “Rubicon”, “our”, “us”, or “we”). This Privacy Policy applies to personal information we obtain about individuals: (i) on https://rubiconcarbon.com and any other Rubicon-owned websites or online services that links to this Privacy Policy (collectively, the “Site”); (ii) who are representatives of our vendors; (iii) who provide business contact information to us; (iv) who apply for a job with us; and (v) who register for an account with us or submit information to us for the purposes of obtaining our services or products (including, information provided to comply with anti-money laundering and “know your customer” requirements), in each case, directly or through our third party service providers. In this Privacy Policy, we describe the types of personal information we collect, how we may use the personal information, with whom we may share it and the choices available to you. We also describe the measures we take to safeguard the personal information and tell you how to contact us about our privacy practices. Please read this Privacy Policy carefully.
In addition to this Privacy Policy, different privacy notices may apply to you depending on your location or relationship with Rubicon.
If you are a California consumer, please refer to our California Consumer Privacy Statement for more information about your privacy rights.
If you are an individual located in the the European Union (“EU”), the European Economic Area (“EEA”), or the United Kingdom (“UK”), please refer to our EU and UK Privacy Statement for more information about your privacy rights and how to exercise them, to the extent that EU and UK Privacy Laws (as defined therein) applies.
Capacity
You represent to Rubicon that you have the authority to visit the Site according to the Terms of Use. The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn that we have collected or received personal information from an individual under the age of 18, we will delete that information.
Personal Information We Collect and How We Collect It
You may choose to provide us with your personal information when you visit the Site or interact directly with us or indirectly via our third party service providers (including Greenhouse Software, Inc. and Rialto Markets LLC), for example in connection with an inquiry, job application, account registration, or in connection with complying with applicable legal requirements, relevant industry standards and policies (including our anti-money laundering and “know your customer” checks). Such personal data may include your full name, date of birth, company name, job title, email address, phone number and government ID. In addition, when you use our Site, we may (ourselves or through a third-party vendor) automatically gather information about your devices and your usage of the Site, such as your IP address, identifiers associated with your device, browser and device characteristics, website preferences, information regarding websites accessed immediately before and after your visit to the Site, the date and time of your visit to the Site, and information about how you navigate our Site.
We collect personal information from third parties, such as a resume sent to us by recruiting firms, background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.
We may also collect the personal information of employees of our vendors (i.e., basic identifying and contact information, including name, title, work email address, work postal address, and/or work telephone number, as appropriate) from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such vendor.
Information regarding how you access the Site (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the Site, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of the Site. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
Some internet browsers have incorporated “Do Not Track“ features. Most of these features, when turned on, send a signal or preference (the “DNT Signal“) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
How We Use the Personal Information We Collect
We may use the personal information we collect about you to:
- Provide our Site or our other products and services;
- Communicate with you;
- Establish and manage our business relationships;
- Personalize your experience with us, including on the Site;
- Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
- Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Site, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; performing other internal functions; evaluating job applications; and to conduct due diligence activities in connection with an actual or prospective corporate transaction to which we are party);
- Maintain and enhance the safety and security of our Site and other properties, and prevent misuse;
- Protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and
- Comply with and enforce applicable legal requirements, relevant industy standards and policies.
We also may use the personal information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.
How We Share the Personal Information We Collect
We may share your personal information with our affiliates for the purposes described in this Privacy Policy. We also may share personal information with service providers who perform services on our behalf, such as recruitment service providers, compliance service providers, payment service providers, analytics providers, and hosting providers. To the extent that you provide us with any personal information, we may use such information for Rubicon’s business purposes or as otherwise set out in this Privacy Policy (as supplemented by the California Consumer Privacy Statement and EU and UK Privacy Statement) but will not disclose any personal information about you to anyone, except as permitted or required by law or regulation. We may disclose personal information about you (i) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (ii) when we believe disclosure is necessary or appropriate to protect our rights, prevent physical harm or financial loss or for other matters of public importance, (iii) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (iv) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
How We Protect the Personal Information We Collect
Rubicon maintains technical and organizational measures designed to protect personal information against loss or accidental, unlawful or unauthorized destruction, alteration, access, disclosure and use. Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the Site; any transmission of information or data by you to or through the Site is at your sole risk.
How to Contact Us About Privacy Matters
If you would like to contact us for any reason concerning our privacy practices, please email us at privacy@rubiconcarbon.com
Updates to this Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our personal information practices. We reserve the right to amend this Privacy Policy from time to time by updating this Privacy Policy. Accordingly, users should review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what personal information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use any collected personal information in a manner different from that stated at the time it was collected, we will notify applicable users.
Miscellaneous
The provisions in our Terms of Use are hereby incorporated by reference.
California Consumer Privacy Statement
This California Consumer Privacy Statement supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA“) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Consumer Privacy Statement is otherwise set out in the Privacy Policy.
Notice of Collection and Use of Personal Information
The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on the Site over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details, account name and address (including email address and Internet Protocol address) or similar identifiers | YES |
| B. Other Customer Records | Telephone number and personal information provided in connection with obtaining account access | YES |
| F. Internet or other similar network activity | Information regarding your use of the Site (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
| I. Professional or employment-related information | Current or past job history or performance evaluations | YES |
We may use (and may have used during the 12-month period prior to the effective date of this California Consumer Privacy Statement) your personal information for the purposes described in the Privacy Policy and for the following business purposes specified in the CCPA:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, auditing compliance.
- Short-term, transient use.
- 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.
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services.
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions.
- As reasonably necessary and proportionate to ensure the physical safety of natural persons.
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us).
- To perform services on behalf of our business.
- To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, or to improve, upgrade, or enhance such service or device.
We retain the categories of personal information set forth above only as long as is reasonably necessary for those purposes also set forth above, except as may be required under applicable law, court order or government regulations.
Sources of Personal Information
Our Privacy Policy sets out sources of personal information in the Personal Information We Collect and How We Collect It section. We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
Who do we disclose your personal information to?
We do not share (i.e., disclosed to a third party for the purposes of cross context behavioral advertising) or sell any of the personal information we collect about you to third parties. In the preceding twelve (12) months, we have not sold or shared any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers. Within the last twelve (12) months, we have disclosed personal information collected in connection with the Site for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
|---|---|
| A. Identifiers | Our affiliates, vendors, broker-dealers, advisors, lenders, banks, consultants, self-regulatory organizations, service providers (including recruitment service providers, compliance service providers, payment service providers, analytics providers, and hosting providers), auditors and law firms. |
| B. Other Customer Records | None |
| F. Internet or other similar network activity | Our affiliates, vendors, broker-dealers, advisors, lenders, banks, consultants, self-regulatory organizations, service providers (including recruitment service providers, compliance service providers, payment service providers, analytics providers, and hosting providers), auditors and law firms. |
| I. Professional or employment-related information | Our affiliates, vendors, service providers (including recruitment service providers, compliance service providers, payment service providers, analytics providers, and hosting providers, and law firms). |
California Consumer Privacy Rights
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the ‘How to Contact Us About This Statement’ section below.
How to Contact Us About This Statement
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Email us at: privacy@rubiconcarbon.com
Within 10 business days, we will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your user portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact us at at privacy@rubiconcarbon.com with any questions about this California Consumer Privacy Statement.
EU and UK Privacy Statement
This EU and UK Privacy Statement supplements the Privacy Policy with respect to individuals located in the EU, the EEA, or the UK, to the extent that EU and UK data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK implementation of the GDPR, and the UK Data Protection Act 2018 (collectively, “EU and UK Privacy Laws”) applies to the personal data processing activities set out in the Privacy Policy. Information that is required to be disclosed to individuals located in the EU, EEA or UK that is not set out in this EU and UK Privacy Statement is otherwise set out in the Privacy Policy.
For the purposes of the EU and UK Privacy Laws, Rubicon Carbon, LLC and/or one or more of its affiliates is the data controller of any personal data collected or processed by us in respect of visitors to the Site, representatives of our vendors, and job applicants. If you have any questions regarding our use of your personal data, or this EU and UK Privacy Statement, please contact us at privacy@rubiconcarbon.com.
Personal Data We Process
Our Privacy Policy sets out Personal Information We Collect and How We Collect It. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.).
How We Use Your Personal Data
Our Privacy Policy sets out How We Use the Personal Information We Collect. We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data, including our legitimate interests, contractual necessity and as required by applicable law, as further set out below:
| Purpose | Legal Basis |
|---|---|
| Provide our Site or our other products and services | Contractual necessity; and/or our legitimate interest in operating our business |
| Communicate with you | |
| Establish and manage our business relationships | Our legitimate interest in operating our business |
| Personalize your experience with us, including on the Site | |
| Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information) | |
| Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Site, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; performing other internal functions; evaluating job applications; and to conduct due diligence activities in connection with an actual or prospective corporate transaction to which we are party). | Legal requirement; and/or our legitimate interest in operating our business |
| Maintain and enhance the safety and security of our Site and other properties, and prevent misuse | |
| Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities | |
| Comply with and enforce applicable legal requirements, relevant industry standards and policies (including anti-money laundering and “know your customer” checks). |
No automated decision-making, including profiling, is used by us when processing your personal data.
Disclosure and Transfer of Personal Data
Our Privacy Policy sets out How We Share the Personal Information We Collect. To the extent your personal data is transferred to countries outside of the EU, EEA and UK, such transfers will only be made in accordance with EU and UK Privacy Laws. For further information about the safeguards/derogations used, please contact us at privacy@rubiconcarbon.com.
Security and Retention of Personal Data
We are committed to protecting the personal data you entrust to us. Our Privacy Policy sets out How We Protect the Personal Information We Collect.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EU and UK Privacy Statement, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact us at privacy@rubiconcarbon.com.
Cookies
Our Privacy Policy sets out information relating to our use of cookies (see Personal Information We Collect and How We Collect It). We use the following cookies on the Site:
| Cookie | Description |
|---|---|
| Cookie Consent cookieConsent |
Used for: User cookie consent |
| A cookie to remember that a user has accepted the cookie disclaimer when the website first loads | |
| Expires after 90 days | |
| Google Analytics _ga |
Used for: Performance |
| This cookie name is associated with the Google Analytics software, which collects statistical usage and telemetry information for apps. This is a unique user identifier cookie enabling counting of the number of users accessing the application over time. | |
| Expires after 2 years | |
| Google Analytics _ga_LCDZ20F8F7 |
Used for: Analytics |
| This cookie name is associated with the Google Analytics software, which collects statistical usage and telemetry information for apps. This is a unique anonymous session identifier cookie. | |
| Expires after 2 years | |
| LinkedIn Cookie lang |
Used for: Analytics |
| Used to remember a user’s language setting to ensure LinkedIn.com displays in the language selected by the user in their settings. | |
| Expires when sessions ends | |
| LinkedIn Cookie lidc |
Used for: Analytics |
| To facilitate data center selection | |
| Expires after 24 hours | |
| LinkedIn Cookie bcookie |
Used for: Analytics |
| Browser Identifier cookie to uniquely identify devices accessing LinkedIn to detect abuse on the platform | |
| Expires after 1 year | |
| LinkedIn Cookie li_sugr |
Used for: Analytics |
| Used to make a probabilistic match of a user&squo;s identity outside the Designated Countries | |
| Expires after 90 days | |
| LinkedIn Cookie AnalyticsSyncHistory |
Used for: Analytics |
| Used to store information about the time a sync took place with the lms_analytics cookie | |
| Expires after 30 days | |
| LinkedIn Cookie UserMatchHistory |
Used for: Analytics |
| Used for id sync process. It stores the last sync time to avoid repeating the syncing process in a frequent manner | |
| Expires after 30 days | |
| LinkedIn Cookie U |
Used for: Analytics |
| Browser Identifier for users outside the Designated Countries | |
| Expires after 3 months | |
| LinkedIn Cookie ln_or |
Used for: Analytics |
| Used to determine if Oribi analytics can be carried out on a specific domain | |
| Expires after 1 day | |
| LinkedIn Cookie liap |
Used for: Analytics |
| Used by non-www.domains to denote the logged in status of a member | |
| Expires after 1 year | |
| LinkedIn Cookie lms_ads |
Used for: Analytics |
| Used to identify LinkedIn Members off LinkedIn for advertising | |
| Expires after 30 days |
Your Rights
Subject to the EU and UK Privacy Laws, you may have the right to access the personal data we hold about you, and control the way in which and what personal data we store and process about you, as set out below. To exercise these rights and controls, please contact us at privacy@rubiconcarbon.com.
- Access: You have the right to ask for a copy of the personal data that we hold and process about you free of charge, however we may charge a “reasonable fee”, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal data if the information we hold and process about you is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal data any more, you may request that we delete it. Please note that the right to deletion is not absolute and it may not always be possible to delete personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, deletion of personal data may result in the inability for us to fulfil the purposes described in this EU and UK Privacy Statement.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawl of consent: If you previously gave us, and we rely on, your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
How to Contact Us About EU and UK Privacy Matters
If you have any questions or concerns about this EU and UK Privacy Statement or our privacy practices, please contact us at privacy@rubiconcarbon.com.
Updates to this EU and UK Privacy Statement
This EU and UK Privacy Statement may be updated periodically to reflect changes in our personal data practices. We reserve the right to amend this EU and UK Privacy Statement from time to time by updating this EU and UK Privacy Statement. Accordingly, users should review this EU and UK Privacy Statement regularly. If we decide to change this EU and UK Privacy Statement, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users.
Complaints
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority.