Revised: January, 2024

RKI Apps Inc. (“we” or “us”) respects the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use or access the SocialLadder application along with any related websites, services or products (collectively, the “App”) delivered to you by us. This Privacy Policy also describes your choices regarding use, access, correction and deletion of your personal information. Please read this Privacy Policy carefully. By using the App, you consent to the collection and use of your information by us as set out in this Privacy Policy. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT PERMITTED TO USE OR ACCESS THE APP.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the App, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on or through the App includes:

Personal Data

Personally identifiable information, such as your name, postal address, email address, and telephone number, and demographic information, such as your age, gender, and interests, that you may voluntarily give to us when you choose to participate in various activities related to the App. This may also include personally identifiable information about or contained in social media accounts that you register for the App through or otherwise provide to us in connection with the App. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the App.

Derivative Data

Information our servers automatically collect when you access the App, such as IP address, device ID, browser type, operating system, access times, and pages you have viewed directly before and after accessing the App.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information collected in other ways or received from third parties. It helps us to improve the App and to deliver a better and more personalized service.

The technologies we may use for this automatic data collection may include cookies, pixel tags and other technologies. To find out more about the use of cookies and how you can manage them, please read our Cookie Policy.

Financial Data

Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from or through the App.

USE OF PERSONAL INFORMATION

We and our service providers use personal information for our legitimate business purposes, including the following:

Providing the functionality of the App and fulfilling your requests

 

• • To respond to your inquiries, fulfill your requests, complete your transactions and provide you with related customer service.

• • To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.

Analysis of personal information for business reporting and providing personalized services

 

• • To personalize your experience on the App by presenting products and offers tailored to you.

Accomplishing our business purposes

 

• • For data analysis, such as to improve the efficiency of our App;

• • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;

• • For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft;

• • For developing new products and services;

• • For enhancing, improving, or modifying our App;

• • For identifying usage trends, such as understanding which parts of our App are of most interest to users;

• • For determining the effectiveness of our promotional campaigns; and

• • For operating and expanding our business activities.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or because we have a legitimate business interest.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, or safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

Third-Party Service Providers and Partners

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, we may share your information with third parties for marketing purposes, as permitted by law.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners, including Brands (as defined in our Terms and Conditions), to offer you certain products, services or promotions.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

California Privacy Notice

If you are a California resident, please see our Privacy Notice for California Residents, which is incorporated into this privacy policy by this reference.

THIRD-PARTY WEBSITES

The App may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the App, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot protect the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the App.

RETENTION PERIOD

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you, when we have legal obligation to which we are subject, or as advisable in light of legal requirements.

SECURITY OF YOUR INFORMATION

We use administrative, technical and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

JURISDICTION AND CROSS-BORDER TRANSFER

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

EU-US DATA PRIVACY FRAMEWORK / SWISS-US DATA PRIVACY FRAMEWORK

RKI Apps Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. RKI Apps Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. RKI Apps Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

RKI Apps Inc. is responsible for the processing of personal data it receives, under each Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. RKI Apps Inc. complies with the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. RKI Apps Inc. is liable for any processing of personal information by such third parties that is inconsistent with the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles unless it is not responsible for the event giving rise to any alleged damage.

With respect to personal data received or transferred pursuant to the EU-U.S. DPF and the Swiss-U.S. DPF, RKI Apps Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, RKI Apps Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, RKI Apps Inc. commits to resolve complaints about or collection or use of your personal information. Individuals with inquiries or complaints about regarding our DPF compliance should first contact RKI Apps Inc. at socialladder@socialladderapp.com.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, RKI Apps Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF.

Under certain conditions, the EU-U.S. DPF and/or the Swiss-U.S. DPF provides the right to invoke binding arbitration when other dispute resolution procedures have not provided resolution. This is described in Annex I to the DPF Principles.

POLICY FOR CHILDREN

The App is not intended for children under 13 years of age. We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

SENSITIVE INFORMATION

You may not send us any sensitive personal information (e.g., social security number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will revise this Privacy Policy accordingly.

RIGHTS WITH RESPECT TO YOUR INFORMATION

Upon request, RKI Apps Inc. will provide you with information about whether we hold any of your personal information. You may access, correct, obtain a copy of or request deletion of your personal information by logging into your account or by contacting us at socialladder@socialladderapp.com, you may also request deletion by clicking the “Delete Account” button inside the mobile app under the “More” tab.  We will respond to your request within a reasonable timeframe. In certain circumstances, we may be required by law to retain your personal information, or we may need to retain your personal information in order to continue providing a service.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here.

CHOICES REGARDING YOUR INFORMATION

RKI Apps Inc. ensures that it uses and discloses personal information in ways that are consistent with your expectations and choices. RKI Apps Inc. provides individuals the opportunity to choose (opt out) whether their personal information is to be (a) disclosed to a third party or (b) used for a purpose that is materially different from the purpose(s) for which it was collected or subsequently authorized. Individuals will be provided with clear, conspicuous and readily available mechanisms to exercise their choice. To do so, please email us your request any time at socialladder@socialladderapp.com, and we will respond to your request within a reasonable timeframe.

Account Information

You may at any time review or change the information in your account or terminate your account by emailing us at socialladder@socialladderapp.com or by visiting the Settings section of the App.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by emailing us at socialladder@socialladderapp.com or by visiting your profile settings page on the App.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

Jurisdiction and Cross-Border Transfer Representation for data subjects in the EU

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/15582735049

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at socialladder@socialladderapp.com or at RKI Apps Inc.(dba SocialLadder), 3401 Market St. Suite 200, Philadelphia, PA, 19104

January, 2024