Rainlight’s General Privacy Policy

Version 1.0 | Rev 25 May 2018

Thank you for visiting rainlightstudio.com. Rainlight’s General Privacy Policy sets out how Rainlight Studio LLC, ( “Rainlight”, “we” or “us”), process the personal information of our website visitors, clients, subconsultants and other third parties. It is not the exclusive description of how Rainlight processes personal information of individuals. If you are an employee, information on how Rainlight handles your personal data has been notified to you and is set out in the Corporate Integrity Handbook and your local Employee Handbook. If you are a prospective employee or job applicant, information on how Rainlight handles your personal data is set out in Rainlight’s Recruitment Privacy Statement incorporated in your application for employment. If you are a third-party vendor or subconsultant, information on Rainlight’s rights and your obligations regarding personal data provided to you by us is set out in Rainlight’s Third-Party Data Protection Addendum. Collectively, these policies form Rainlight’s Global Privacy Policy. For questions about Rainlight’s Global Privacy Policy, please contact us by email at privacy@rainlightstudio.com or by mail to Rainlight Studio LLC, 10 South Broadway, Suite 200, St. Louis, MO 63102; Attention: Rainlight Privacy.

1.0            HOW INFORMATION IS COLLECTED

Rainlight typically collects personal information directly from the individual to whom it relates, except where that individual has consented to Rainlight collecting the personal information from a third-party or the law otherwise permits Rainlight to do so.

Rainlight will collect and store your personal information when you interact with rainlightstudio.com. We may ask you to voluntarily provide information, including personal information, to us by: (a) emailing Rainlight about our products or services, employment or internship opportunities, marketing, media requests, and other business matters; (b) by registering online to attend a Rainlight-sponsored event; or (c) downloading one of our online publications.

Other than as stated above, we do not collect information related to your use of rainlightstudio.com.

Rainlight uses World-Check by Thomson Reuters® to obtain risk intelligence data associated with new business relationships. Risk intelligence data may include sensitive personal information on companies and individuals such as political activities, criminal allegations or convictions, regulatory inquiries or penalties, precise geolocation information, financial and banking information, reputational information, government issued identification numbers, relationships to sanctioned or otherwise politically exposed persons and organizations, and other similar information.

2.0            TYPES OF PERSONAL INFORMATION COLLECTED

Personal information means any information relating to a person that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your contact details (e.g. name, phone number, address and email address), IP address, language, gender and geolocation.

If you are a client, vendor, designer or manufacturer, personal information that we hold about you may include the same information listed above, along with your date of birth, social media/network accounts, business address, email address, phone number and fax number, function/job title, company, types of products or services provided, and financial compensation. Rainlight may request that you provide additional information such as your company’s legal status, date of incorporation, place of incorporation, your company’s related entities, your company’s shareholding details, your relationship to any government official, your company’s tax identification numbers, country of origin, business and professional licenses, your company’s insurer, broker and insurance policies, and other information you consent to provide us for purposes of performing contracts or services.

We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.

3.0            HOW PERSONAL INFORMATION IS USED

We will use your personal information, and may share your personal information with other parties acting on our behalf, for one or more of the following: (i) to conduct research about the use of our website; (ii) to improve products or services provided by Rainlight; (iii) to assess and respond to a complaint you might make to us; (iv) for our own administrative purposes, including training our staff, conducting internal audits, improving our products or services or transferring assets as part of a sale, purchase or investment in the business; (v) if you are a client, vendor, designer or manufacturer, to perform services or carry out our contract with you; (vi) for market research purposes; (vii) to make informed decisions about business relationships and to prevent inadvertent engagement in illegal or corrupt practices; (ix) to conduct investigations of suspicious or harmful activity; (x) to comply with Rainlight’s regulatory and legal obligations; (xi) to manage risks related to Rainlight’s products and services; and (xii) for marketing purposes. If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law. Rainlight does not sell personal information to others.

4.0            INFORMATION FOR MARKETING PURPOSES

Where you have consented to us using your personal data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Rainlight and its business partners. If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please contact us by email at privacy@rainlightstudio.com  or by mail to Rainlight Studio LLC, 10 South Broadway, Suite 200, Saint Louis, MO 63102; Attention: Rainlight Privacy.

5.0            GROUNDS FOR PROCESSING

To process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include:

  1. Your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
  2. Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your information to prevent or detect fraud or abuses of our website;
  3. Our compliance with a legal obligation to which Rainlight is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
  4. If you are a client, vendor, designer or manufacturer, because processing your personal information is necessary for the performance of a contract or services.

6.0            DISCLOSURE OF YOUR PERSONAL INFORMATION

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third-parties. This will only take place in accordance with the applicable law for the purposes listed above, and pursuant to Rainlight’s Third-Party Data Privacy Addendum. These scenarios include disclosure to: (i) Rainlight’s affiliates; (ii) outsourced vendors designers or manufacturers to facilitate the provision of our products or services (including other professional service providers); (iii) third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons (including cloud service providers); (iv) another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event; (v) attorneys in connection with negotiation of a contract, dispute resolution, and other legal advice; (vi) tax advisors for purposes of tax filings, obtaining tax credits, negotiating tax liabilities, and other tax advice; (vii) public authorities where we are required by law to do so; and (viii) any other third party where you have provided your consent.  Further, we may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Rainlight.

7.0            INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

Rainlight is designated as an “Other Covered Entity” under the U.S. Privacy Shield certification of HOK Group, Inc. As such, Rainlight adheres to the Privacy Shield Principles regarding the collection, use and retention of personal information transferred from the European Union (“EU”) to the United States. Rainlight commits to cooperate with EU data protection authorities and comply with advice given by such authorities with regard to personal information (including human resources data) transferred from the EU in the context of the employment relationship. If there is conflict between the terms of Rainlight’s Global Privacy Policy and the Privacy Shield Principles, the latter shall govern. Rainlight’s status as an Other Covered Entity is subject to enforcement by the U.S. Federal Trade Commission. To learn more about the Privacy Shield program, please visit http://www.privacyshield.gov.

Participating organizations are deemed to have “adequate” privacy protection for the transfer of personal information outside of the EU under the General Data Protection Regulation (“GDPR”). As a result, EU member state requirements for prior approval of international data transfers to Rainlight are waived. In cases of onward transfers of data, received pursuant to the EU-U.S. Privacy Shield, Rainlight is potentially liable under the GDPR.

Questions and complaints regarding Rainlight’s Global Privacy Policy or its Privacy Shield compliance should be directed to us by e-mail at privacy@rainlightstudio.com or by mail to Rainlight Studio LLC, 10 South Broadway, Suite 200, St. Louis, Missouri, USA, 63102; Attention: Rainlight Privacy. If Rainlight does not timely acknowledge a complaint, or if we have not satisfactorily addressed a complaint, EU residents may: (i) submit their complaint to their local data protection authority for referral to the U.S. Department of Commerce; or (ii) seek a non-monetary remedy through binding arbitration administered by the International Centre for Dispute Resolution ® – American Arbitration Association ® (“ICDR-AAA”) in accordance with the Privacy Shield Principles.  The services of ICDR-AAA are provided at no cost to EU residents.  To learn more about the independent recourse mechanism provided by the ICDR-AAA, please visit http://go.adr.org/privacyshield.html.

8.0            RETENTION OF PERSONAL INFORMATION

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in Rainlight’s Global Privacy Policy (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

9.0            CONFIDENTIALITY AND SECURITY

Rainlight is committed to: (i) seeking to safeguard all personal information that you provide to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, subsidiary companies and third parties who need to know that information for the purposes set out in Rainlight’s Global Privacy Policy.

10.0         EU RESIDENT RIGHTS

The EU GDPR provides EU residents with certain rights discussed below. EU residents may contact Rainlight regarding any of these rights by email at privacy@rainlightstudio.com or by mail to Rainlight Studio LLC , 10 South Broadway, Suite 200, St. Louis, Missouri, USA, 63102; Attention: Rainlight Privacy. Rainlight will respond within a reasonable time period, in any event, within any time period specified by law. Persons exercising these rights will be required to submit a proof of identity. If you are an EU resident, you have the right to:

  1. Obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you by contacting us as directed above.
  2. Correct your personal information. You may request that we rectify any inaccurate and/or complete any incomplete personal information by contacting us as directed above. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
  3. Withdraw your consent to processing. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time by contacting us as directed above. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
  4. Object to processing. You may, as permitted by law, request that we stop processing your personal information by contacting us as directed above.
  5. Erasure. You may request that we erase your personal information by contacting us as directed above. We will comply, unless there is a lawful reason for not doing so.
  6. Lodge a complaint. We suggest that you first contact us as directed above regarding any questions or complaints in relation to your rights or how we process your personal information. However, this does not limit your right to contact your local data protection authority directly.

11.0         LINKS

Our website may provide hyperlinks to websites owned and controlled by others. Rainlight is not responsible for the privacy practices of any website that it does not own or otherwise control.

12.0         THIRD PARTIES

Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.

13.0         COMPLIANCE WITH PRIVACY LAWS

Rainlight complies with the data protection and privacy laws to which it is subject. You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them. You should also be aware that privacy laws in various jurisdictions may change from time to time. Notwithstanding contrary terms in Rainlight’s Global Privacy Policy, Rainlight accepts no obligations with respect to the handling of personal information other than those mandated by law in the country which has, or counties which have jurisdiction over Rainlight in any given circumstances.

14.0         CHANGES TO THIS POLICY

As we strive to improve our practices, we may review Rainlight’s General Privacy Policy from time to time.  We reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy on our website. It is your responsibility to check our policy each time before you access our website for any changes.