RDM Associates and its affiliates (“RDM Associates”, “we”, “us” or “our”) respect the privacy of our website visitors (“you”, “your”, “visitor”, or “user”). This privacy policy (and as amended from time to time as posted on our website https://rdma.com/privacy-policy) (“Privacy Policy”) describes the types of information we may or do collect from you or that you may provide when you visit or use our rdma.com website or mobile website (“Website”) which describes certain of our services (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. This Privacy Policy applies to the data collected by us through our Website, and not by any other method or source. If you are a job applicant, the information we collect and how it is used is described in a separate section below.

What Information Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information. Such information may include name, mailing address, email address, telephone number, and other information which identifies you as a specific individual, and related information (“Personal Information”). Please see additional information below on the information we collect. For this Privacy Policy the definition of “Personal Information” is the definition under the state or other law applicable to the person whose data is collected; however, for California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information.

If, for example, you are applying for employment via our Website, we may obtain information from third parties about membership, licensing, accreditation, certification, professional, and/or employment as part of a background check, among other information, as part of the application process.

Personal Information does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

Individuals under the Age of 18

We do not knowingly collect, solicit, or maintain Personal Information from anyone under the age of 18. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under the age of 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

Changes to Our Privacy Policy

We are constantly working to improve our Website and Services, and we may occasionally need to change this Privacy Policy. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates.

Personal Information We Collect

Information You Provide Us. We may collect several categories of Personal Information from and about you. Information we collect which you directly provide to us, such as through our Contact Us website page may include: name, email address, phone, company name, and title.

Our Work Here page has information about employment opportunities with us and contains a link which directs you to a third party’s website (but which contains our brands) through which you can submit an application for employment. This application will request certain Personal Information about you. The Career Opportunities Privacy Policy set forth at the end of this Privacy Policy applies to our Careers Website and information collecting/processing, in addition to this Privacy Policy. That third party’s website has its own terms of use and privacy policy which you should review prior to submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
•  Behavioral Trackingsome text
  • We may use these technologies to collect information about your online activities over time and across third-party websites or other online services or associate Personal Information with other information collected in this manner.

The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up your searches; and/or, (d) recognize you when you return to our Website.

Cookie Notice/Policy

The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIFs, and/or IP addresses. Each of these is discussed below.

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari, or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies

These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable us and our service providers to find out whether you have accessed one of our Websites from their site. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font, and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies to implement tracking technology on our Website. This tracking uses De-Identified Personal Information data. We will not combine this data with your other Personal Information without your express permission. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

GIF. We may use tiny images known as clear GIFs to track the behavior of users, including statistics on who opens our emails.

IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Other Tracking Technologies

Google

Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand the use of our Website and Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers the use of cookies by us only and not the use of cookies by third parties.

Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements and principles are set forth here. They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display

Network Impression Reporting.

Google DART Cookie. Google, as a third-party vendor, uses cookies to serve ads on our Website. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our Website and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.

Google DoubleClick Cookie. We work with DoubleClick Cookie Google, a third-party vendor, which uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page here.

Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, both of which are subject to their own terms of use and privacy policy.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt-out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

• To present our Website and its contents to you.
• To provide you with information and respond to your questions on Services that you request from us and information on new services.
• To notify you about information regarding or changes to our Website, our policies, terms, or any Services we offer or provide.
• To process Personal Information or other information that you submit through to us.
• To allow you to participate in interactive features on our Website.
• To operate, maintain, provide, enhance, and improve our Website and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.
• For internal purposes, such as Website and system administration or internal audits and reviews.
• For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
• To operate, maintain, and provide to you the features and functionality of the Services.
• To provide statistics about the usage levels of the Website and other related information to our service providers.
• To notify you of data privacy incidents or provide you with legally required information.
• To fulfill any other purpose for which you provide Personal Information.
• In any other way, we may describe and for which we obtain your consent when you provide the information and you give your consent.

How We Share Your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:

• Data storage or hosting providers for the secure storage and transmission of your data
• Database and software service providers for the management and tracking of your data
• Technology providers who assist in the development and management of our Website
• Identity management providers for authentication purposes
• Legal and compliance consultants, such as external counsel, external auditors, or tax consultants

Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third-party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, analyzing data, screening checks, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing search results and links, etc. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers); however, all such information will remain in the United States.

Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website or our Services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

Security

We have implemented measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website or used with our Services.

Data Retention

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as we have a legitimate business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Privacy Notice for California Residents

The following in this section applies only to California residents.

California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575- 22578, available here):

CalOPPA applies only to companies which collect the Personal Information of California residents.

How We Respond to Do Not Track Signals.

CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, see www.donottrack.us. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Third-Party Behavioral Tracking. We allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ clicking or browsing patterns.

California Consumer Privacy Act of 2018 (“CCPA”, available here): This law provides California residents with additional rights regarding our use of their Personal Information.

WE DO NOT SELL (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION, PERIOD.

Non-Discrimination

We will not discriminate against you simply for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including by refusing to grant discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notices; Opting Out

By providing us with your email address you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service or the Website to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request. Opting out may prevent you from receiving email messages. You may not opt out of Service-related emails.

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