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Privacy Policy
 
Version 1.0
 
Last revised on: October 14, 2019

This  Privacy   Policy  (the “ Policy ”) discloses the privacy practices for the  https://www.rubinreport.com site and various related products and services offered through the site, including without limitation any integrated iOS or Android mobile applications (together referred to as the “ Site ”). ‘Emma Dog Productions, Inc’ (“ Company ” or “ us ” or “ we ” or “ our ”), the provider of the Site, is committed to protecting your privacy online. Please read the information below carefully regarding your use of the Site.

You acknowledge that this  Privacy Policy  governs your use of the Site along with our Terms of Use, available at https://www.rubinreport.com/terms , and that by accessing or using the Site, you agree to be bound by all terms and conditions of both this Privacy Policy and our Terms of Use. Please read the Terms of Use carefully, as it contains procedures for MANDATORY BINDING ARBITRATION AND A CLASS ACTION WAIVER which shall apply to all disputes except as otherwise provided herein. Any capitalized terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use.

IF YOU DO NOT AGREE TO OUR TERMS OF USE AND THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SITE. YOUR USE OF THE SITE CONSTITUTES YOUR SPECIFIC, INFORMED CONSENT AND AGREEMENT THAT YOUR PERSONAL INFORMATION AND DATA MAY BE PROCESSED IN ACCORDANCE WITH THIS POLICY.

We reserve the right to change this  Privacy   Policy  at any time. We also reserve the right in the event of our bankruptcy, sale, merger, acquisition, or similar transactions, to transfer any information we have received from you to the transferee in such transaction, provided, however, that unless legally prohibited from doing so, we will require such transferee to honor the terms of this Privacy Policy as it applies to any user of the Site before the effective date of such transfer.

Changes, modifications, additions or deletions to this Policy shall be effective immediately upon notice thereof, which may be given by various means including but not limited to sending an email to the email address you provide us and/or posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered user, review the Site and this Privacy Policy periodically, and to be aware of any modifications. YOUR CONTINUED USE OF THE SITE AFTER SUCH MODIFICATIONS WILL CONSTITUTE YOUR: (A) ACKNOWLEDGMENT OF THE MODIFIED POLICY; AND (B) AGREEMENT TO ABIDE AND BE BOUND BY THE MODIFIED POLICY.

1. Types of Information Collected
In order to better provide you with the services offered through the Site, we collect two types of information about our users: Personally Identifiable Information and Nonpersonally Identifiable Information. When you consent and agree to provide us with certain of your Personally Identifiable Information and/or Nonpersonally Identifiable Information directly, we act as a “Controller” of such information.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on the Site, such as registering for an Account, submitting content and/or posting content in discussion forums or other public areas, entering a contest, sweepstakes or engaging in other activities, or sending us feedback, we may ask you to provide certain information about yourself, for example, by filling out and submitting online forms. It is completely optional for you to engage in these activities; however, in order to participate in these activities, we require your opt-in consent prior to collection and processing of such information.

Nonpersonally Identifiable Information:  This refers to information that does not by itself identify a specific individual. We may gather certain information about you based upon how you use the Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis and we may combine and synchronize Nonpersonally Identifiable Information with information you actively submit (including Personally Identifiable Information), and/or with information that we receive from third parties. This information may include a website’s Uniform Resource Locator (“URL”) that you just came from when navigating to the Site, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. Additionally, when visiting the Site or reviewing our emails, we may store information about your IP Address and your interactions with our Site and our emails, i.e., through beacons, pixels or similar technologies.

For your reference,  a URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

2. Collection Methods and Use of Information
We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you: (a) register for our services and register your email address with us; (b) enter sweepstakes or contests sponsored by us or one of our partners, or perform actions on the Site to receive certain incentives; (c) sign up for special offers from us or selected third parties who are our partners; (d) create a user profile with your Account, send messages, submit forms, or transmit other information by email, phone, or other methods of communication in connection with the Site. We may also collect information from you at other points on our Site which state that such information is being collected.

In addition, we may also collect, or our third-party content server may collect, certain Non-personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, our software, to administer our Site, and to gather demographic information.

We will primarily use your Personally Identifiable Information to provide our services to you, as required by our agreements with you. We will also use Personally Identifiable Information and Nonpersonally Identifiable Information to enhance the operation of our Site, improve our marketing and promotional efforts (e.g., through Facebook Pixel), reduce fraud or illegal activity, statistically analyze Site use (e.g., through Google Analytics), improve our product and service offerings, and customize and improve our Site’s content, layout, and services (for example, by setting session cookies so that you do not have to repeatedly enter the same information).

Note that the Google Analytics and Facebook Pixel software collects and stores information in accordance with their own privacy policies, available at https://policies.google.com/privacy  and https://www.facebook.com/privacy/explanation , respectively, which information may include your Personally Identifiable Information and Nonpersonally Identifiable Information. Therefore, please review Google’s and Facebook’s respective policies carefully and note that by using our Site, you are indicating that you agree to these policies.

We may use Personally Identifiable Information to deliver information to you, including without limitation information about topics which may interest you, marketing and promotional notices, and to contact you regarding administrative, security, or other notices. You hereby consent to receive such notices from us. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Terms of Use and this Policy.

You may opt-out from receiving email notifications from us which are for marketing or promotional purposes (by following the instructions made available on the Site or by email), but you may not opt-out of our administrative, security, or similar notices, though you may delete your Account with us at any time, after which time you will no longer receive such notices from us.

You may also revoke your consent or otherwise object to our processing of your Personally Identifiable Information at any time, on any legitimate basis, by contacting us at support@daverubin.com, in which case we will apply your preferences to all subsequent activities in connection with your Account, provided, however, that this may limit your ability to use certain aspects of the Site.

3. Release of Information
We do not sell, trade, or rent your Personally Identifiable Information to others without your consent. We do provide some of our services through contractual arrangements with third-party services providers and/or data processors (collectively, “Subprocessor” and “Subprocessors”), as most websites do today. We and our Subprocessors may use your Personally Identifiable Information only to operate our Site and to deliver their services to you; for example, domain hosting, website security, data analytics, information technology and infrastructure, technology maintenance, email deliverability, customer service, payment and redemption of incentives (if any), and related services. We may also share your Personally Identifiable Information and Nonpersonally Identifiable Information to develop statistics about online activity on an aggregated basis, or otherwise with your consent. A list of our current Subprocessors will be made available upon request by sending an email to support@daverubin.com.

Please note that in connection with your Personally Identifiable Information and/or Nonpersonally Identifiable Information, such information may be transferred to and stored in a country other than your country of residence, including without limitation the United States. If you have any questions or concerns regarding the manner in which such information may be shared and stored, please contact us at support@daverubin.com  or you may also opt-out completely by deleting your Account on the Site. We will encourage all our third-party service partners to adopt and post  privacy   policies . However, the use of your Personally Identifiable Information and/or Nonpersonally Identifiable Information by our third-party service partners is governed by the  privacy   policies of those third-party service partners and therefore is not subject to our complete control.

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a valid court order or subpoena, or to reasonably cooperate with a law enforcement investigation, or to protect the safety and integrity of our Site, users of our Site, the public, or other parties as deemed appropriate in our sole discretion. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. You hereby consent to our sharing of your Personally Identifiable Information and Nonpersonally Identifiable Information under the particular circumstances set forth in this Section.

4. Updating and Correcting Information
We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by editing your Account information in accordance with instructions posted elsewhere on the Site or by contacting us directly. You may also access and correct your personal information and privacy preferences by writing us at:
 
support@daverubin.com

Please include your name, address, and/or email address when you contact us.
 
We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past financial transactions, you cannot delete information associated with past financial transactions on the Site. In addition, it may be impossible to completely delete your information without some residual information because of backups.

5. User Choices on Collection and Use of Information
We may, from time to time, send you email, push notifications, and/or SMS text messages regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail, email, push notifications, and/or SMS text messages regarding certain products, services, and information that we feel may be of interest to you. Only Company (or agents working on behalf of Company and under confidentiality agreements) will send you these communications and only if you indicated that you do not object to such communications. If you do not want to receive such communications, simply tell us when you give us your personal information, or in the case of SMS text messages, simply reply with the word “STOP” to any SMS text message you receive; or, at any time, you can easily edit your Account information to no longer receive such offers and similar communications.
You also have choices with respect to cookies, as described below in Section 7 (“Cookies”). By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Site may not work properly in your case.
 
Your personal data is yours and you have rights over it, including but not limited to: (a) the right to be informed about the collection and use of your personal data; (b) the right of access to your personal data and any supplementary information; (c) the right to have any errors in your personal data rectified; (d) the right to have your personal data erased; (e) the right to block or suppress the processing of your personal data; (f) the right to move, copy, or transfer your personal data from one IT environment to another; (g) the right to object to processing of your personal data in certain circumstances; and (h) rights related to automated decision-making (i.e., where no humans are involved) and profiling (i.e., where certain personal data is processed to evaluate an individual).
 
To manage your data, you can contact us via email at support@daverubin.com with any requests that you may have. While we do not hold personal data any longer than we need to for the purposes set out in this Policy, the duration will depend on your relationship with us.

6. Security of Information
We use our best efforts to ensure that your Personally Identifiable Information is securely stored, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our users is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a unique User ID and password selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure, password protected server that only selected Company personnel and contractors can access. Any personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password. Since this information is not accessible from outside Company you will not be asked to select a password in order to view or modify such information.
 
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through the Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
 
If we become aware of any security breach affecting the Site, we may: (a) notify you via the email address registered with your Account so that you may take whatever protective measures you deem appropriate; and/or (b) post a notice on the Site concerning the security breach. Based upon your country of residence, you may also have a legal right to receive notices of any security breach in writing, in which case you may request such written notice by contacting us at support@daverubin.com.

7. Cookies
When you use our Site we will store cookies on your computer in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies may store randomly assigned user identification numbers, the country where you are located, and your user name to welcome you back to our Site. The cookies make your use of the Site easier, make the Site run more smoothly and help us to maintain a secure Site. We may use, without limitation: session cookies (to operate the Site), preference cookies (to remember your preferences and various settings), and security cookies (to facilitate and ensure secure login and other security features). You are always free to decline our cookies if your browser permits, but some parts of our Site may not work properly in that case.
 
If you have enabled a “Do Not Track” signal via your web browser, we will make reasonable efforts to respond to such signals, but because these signals are not yet uniform, we do not currently respond to all “Do Not Track” signals and therefore you hereby acknowledge and agree that we may not be able to respond to such signals from your web browser.

8. Privacy Policies of Third-Party Sites
Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each such site’s privacy policy separately. We are not responsible for the policies or practices of third parties.

9. International Users
If you are a resident of the EU, our legal basis for using your personal information as described in this Policy is based on that grounds that, as applicable: (a) the use is necessary to fulfill our commitments to you under our Terms of Use, any of our other agreements with you, or to administer your Account; (b) the use is necessary for compliance with a legal obligation; (c) the use is necessary in order to protect your vital interests or those of another person; (d) the use is in our legitimate interests and is not overridden by your privacy rights; and/or (e) you have given us your consent. You have the right to complain to a Data Protection Authority (or other government supervisory authority) about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
 
Please note, however, the Site is operated and hosted from the United States, which has certain laws and regulations concerning the collection, use, and disclosure of personal data which may be less protective than the laws of other countries or regions. Please be advised that if you are located in the European Union, Asia, or other regions outside the United States, you are transferring your Personally Identifiable Information and Nonpersonally Identifiable Information to the United States when you choose to use certain features of the Site. You acknowledge that by accessing or using our Site, you consent to the use of your Personally Identifiable Information and Nonpersonally Identifiable Information for the uses identified in, and in accordance with, this Privacy Policy. PLEASE DO NOT USE OR ACCESS THE SITE IF YOU DO NOT WISH TO TRANSFER YOUR PERSONALLY IDENTIFIABLE INFORMATION AND NONPERSONALLY IDENTIFIABLE INFORMATION TO THE UNITED STATES.
 
TO THE EXTENT PERMITTED BY THE LAW OF YOUR COUNTRY OF RESIDENCE (BUT EXCLUDING THE EUROPEAN UNION), YOU EXPRESSLY WAIVE ANY RIGHTS YOU MAY HAVE TO REQUIRE THAT WE TREAT YOUR  PERSONALLY IDENTIFIABLE INFORMATION OR NONPERSONALLY IDENTIFIABLE INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OTHER THAN THE UNITED STATES.

10. Miscellaneous Privacy Issues
You must be at least 18 years old to have our permission to use the Site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors who are under 18 years of age; therefore, by using the Site you represent that you are at least 18 years old. If you are a parent or legal guardian and believe your child has used the Site without your permission, please contact us immediately at support@daverubin.com so that we may remove all information associated with your child.
 
You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e., your name, email address, etc.) in discussion forums, in comments, or other public areas of the Site, that this information, along with any information disclosed in your communications, can be collected and used by third parties and/or other users of the Site and may result in unsolicited messages from such third parties or other users. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on the Site are made with the understanding that they are accessible to all third parties and other users of the Site. If you do not want your comments to be viewed by third parties or other users of the Site, you are advised not to make any submissions to discussion forums, comment sections, or other public areas on the Site. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or Account information. Please be careful and responsible whenever you’re online.

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