Last Updated: 04/06/2019
RUNABETTERSET, LLC, and its subsidiary RUNABETTERSET LA, LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes (1) the types of information we may collect or that you may provide when you access or use runabetterset.com or rabs.io or rabs.app (the “Website”) and/or download, register with, access, or use the Company’s RABS App (the “App”) (collectively, the “Services”); (2) our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies only to information we collect. This policy DOES NOT apply to information that (1) we collect offline or on any other Company apps or websites, including websites you may access through this App; (2) you provide to or is collected by any third party. Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them
Company’s certification in the Privacy Shield program, as well as the list of other participating businesses, can be found here: https://www.privacyshield.gov/list.
Children Under the Age of 13
The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13 without the explicit consent of a parent/guardian. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
Information We Collect and How We Collect It
We collect information from and about users of our Services:
• Directly from you when you provide it to us, for example when a profile is created.
• Directly from the casting agency, for example when a skin is created.
• Automatically when you use the App or enter information into the App.
Information You Provide to Us
When you download, register with, or use the App, we may ask you or the casting agency or production company to provide information, including:
• any and all personal identification information of an extra including but not limited to name, addresses, phone number, email address, social security number, marital status, tax exemptions, citizenship status, wages, hours worked, passport numbers, country of issuances, driver’s license numbers, any other identification number or expiration date found on an acceptable i-9 identification document, work permits, all images of identification information, and anything else perceived to require discretion or confidentiality; and
• certain information about you, but which individually does not identify you, such as role, wardrobe, props, pay rate, time expected and other profile information that may include your age, location, ethnic group, sex, work history, and emergency contact information.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Details of an extra’s shoot, its scope, hours worked, and other parameters recorded through the App. Extras may be required to provide information on eligibility of employment to use the App.
Automatic Information Collection
When you download, access, and use the App, it may use technology to automatically collect:
• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including logs, and other communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Location Information. This App does not collect real-time information about the location of your device.
Information Collection Technologies
The technologies we use for automatic information collection may include:
• User Input. Extras, casting agencies and production companies will input data.
• Cookies (or mobile cookies). A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your device or browser. However, if you select this setting you may be unable to access certain parts of our App.
• Web Tokens. The device used to access the Services will store the session data locally as a JSON Web Token (“JWT”) which is used to facilitate automatic login.
Known Third-Party Information Collection
When you use the Services, certain known and trusted third parties will have access to your personal information. More specifically, the casting agency or the production company and their affiliates, may access your profile information for the duration of the production project (the “Shoot”). While you will have the ability to edit your profile and change the information you make available, the Company cannot provide any guarantee that agencies and others looking to cast extras will not view, print, remember or otherwise retain the information you originally provided. Moreover, the Company cannot provide any guarantee that such users will not disclose this information to unauthorized third persons.
In contrast, your personal payroll related information and your work eligibility will be only be used by the parties necessary to perform the functions for which this information is being disclosed, including but not limited to Accounts Payable, HR, and Production Management. It will never be disclosed to other users of the site, or non-affiliated third parties, under any circumstances.
Unknown Third-Party Information Collection
Other third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
• Your device manufacturer.
• Your mobile service provider.
• Your internet service provider.
We do not control these third parties’ tracking technologies or how they may be used.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account.
• Carry out our obligations and enforce our rights arising from any contracts, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the Services.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the App End User License Agreement, and for payment processing, billing or collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the App and visiting your account profile page. You may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except upon approval from the production company or agency to delete your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
EU and Swiss Privacy Rights
Company commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, and to comply with the advice given by the panel and/or Commissioner, with regard to human resources data transferred from the EU or Switzerland during the term of your employment on the Production.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal information you provide to us is stored on our secure servers behind firewalls and any confidential information will be encrypted. Our security protocols are consistent with industry best practices and regular reviews and upgrades are made to ensure that we sustain that status. Our practices include the following:
1. Hardware firewall configuration
2. Administrative control of usernames and passwords
3. Encrypted confidential information in storage and at rest
4. Encrypted data transmission with SSL, HTTPS and other encryption tools
5. Use of anti-virus software and firewalls on company devices
6. Static and dynamic testing of code
7. A zero-exploit coding framework
8. Data restricted to need-to-know basis
9. Unique usernames and passwords for each user
10. PCI Level 3 compliant server hosting facility
11. Monitoring access to network resources
12. User and access logs
13. Weekly review of network and network access
14. Cybersecurity best practice training with the application’s administrators and users
15. Cybersecurity best practice training with employees of RunaBetterSet
16. Daily, weekly, monthly server snapshots
17. Restricted firewall port access
18. IP tethered access to development servers and to production mainframe
19. Industry standard data sanitization and deletion protocol
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Onward Transfers to Third Parties
In the context of an onward transfer, a Company ensures third parties acting on their behalf act in a manner consistent with Privacy Shield Principles.
In compliance with the Privacy Shield Principles, Company commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Company at: email@example.com
firstname.lastname@example.org is committed to resolving any inquiries or complaints within 45 days.
Company has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA). If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit, https://www.adr.org/, for more information or to file a complaint. The services AAA are provided at no cost to you.
An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please see Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Should Company be required to disclose your information to a third party for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you, you can opt out of having your information shared. When Company indicates to you that your information will be share for any purpose other than why you have authorized, not including any proceedings required by law, you can opt out by contacting email@example.com, within forty-eight hours of notice. You must indicate in your email your full legal name, your billing address, and providing Company with a clear and definitive reason as to why you are opting out. More information on Privacy Shield Principles can be found: https://www.privacyshield.gov/EU-US-Framework