Privacy Policy

Privacy Policy 

This Privacy Policy (this “Policy”) describes the practices of RAFITServices, LLC, (“RAFIT”) for collecting, using, maintaining, disclosing, and otherwise processing (collectively, “Processing”) the information that we collect from you, as well as how we protect and secure your data.  If you have additional questions regarding your rights under this Policy or any agreement you may have with RAFIT regarding your data, please contact us.  Please read this Policy carefully to understand our Processing of your information and how we will treat it. 

This Policy generally applies to the information that RAFIT Processes and explains how we use the Personal Information we hold on prospective, current, or former customers, and the rights you may have in relation to that Personal Information.  

However, this Policy is subordinate to any specific terms and conditions set forth in any Terms of Use, end user license agreements, or other agreements you may have with RAFIT relating to a particular product, service, or data.  Please visit this website from time to time, as we may update it to reflect changes in the law or our data practices. Further, this Policy applies only to information RAFIT Processes. It does not apply to information collected by RAFIT’s business partners, which may have their own privacy policies that apply to you.  

  1. What does this Privacy Notice cover? 

We take your privacy seriously. This notice:  

  • sets out the types of Personal Information that we collect about you;  
  • describes the sources of the Personal Information we collect about you;  
  • explains how and why we collect and use your Personal Information;  
  • explains when, why, and with whom we will share your Personal Information;  
  • explains the different rights and choices you have when it comes to your Personal Information; and  
  • explains how you can contact us. 
  1. What Personal Information have we collected in the past 12 months? 

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.  

It is routine for us to collect, process and store Personal Information about you over the course of your interactions with us.  

In the past 12 months, we have not sold your Personal Information to any other entity. We do not sell Personal Information to third parties. 

The following chart describes the categories of Personal Information we may have collected about you in the past 12 months and, for each category, where and why we collected it, and the categories of entities with which we may have shared the Personal Information, if at all. 

Category of Personal Information (PI) Sources of Personal Information Purpose of Collection Categories of Entities with Which Personal Information was Shared 
Address and other identifiers such as name, postal address, email address, account name, Social Security and/or Employer Identification number, driver’s license number, MC Number, VIN Number, passport number, or other similar identifiers Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; Through publicly available sources; or From the use of our CCTV cameras, as where we have cameras on our premises, your image and movements may be recorded. to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to deal with administrative matters such as invoicing, renewal or to audit customer transactions to perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers, including accountancy and legal firms, in order to provide us with advice; Service providers, including to provide and support our data management, analytics, security, and storage systems; Our operating and other affiliated companies, for business and operational purposes; and Transaction (merger and acquisition) partners, including to facilitate the diligence, negotiation, and completion phases of transactions contemplated by us, our parent company, or affiliated operating companies. 
Unique electronic identifiers such as IP address, device IDs, session tokens, or other similar identifiers Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; Through publicly available sources; or From the use of our CCTV cameras as described above. to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction partners as described above. 
Financial information Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; or Through publicly available sources. to respond to any questions or concerns you have raised; to deal with administrative matters as described above; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction partners as described above. 
Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; or Through publicly available sources. to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to deal with administrative matters as described above; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction partners as described above. 
Education or other professional information Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; or Through publicly available sources. to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to deal with administrative matters as described above; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction partners as described above. 
Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; Through publicly available sources; or From the use of our CCTV cameras, as where we have cameras on our premises, your image and movements may be recorded. to deal with administrative matters as described above; to carry out anti-money laundering and other compliance checks and controls; or to verify your identity or for other fraud or crime prevention Professional advisers as described above; Service providers as described above; and Our operating and other affiliated companies as described above. 
Biometric information to respond to any questions or concerns you have raised; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; or for internal research, analytics and development. to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; and Our operating and other affiliated companies as described above. 
Geolocation Information Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; Through publicly available sources; or From the use of our CCTV cameras as described above. to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to deal with administrative matters as described above; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls; to verify your identity or for other fraud or crime prevention to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction (merger and acquisition) partners as described above. 
Inferences drawn from Personal Information such as individual profiles, preferences, characteristics, behaviors Directly from you; From your employer; Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; From an agent or third party acting on your behalf as described above; Through publicly available sources; or From the use of our CCTV cameras as described above to contact you to discuss the services or products you receive from us; to respond to any questions or concerns you have raised; to deal with administrative matters as described above; to perform services on our behalf as described above to otherwise carry out our obligations arising under our contract with you and to enforce the same; to carry out anti-money laundering and other compliance checks and controls;/span> to verify your identity or for other fraud or crime prevention to debug errors in our systems; for marketing and advertising purposes; or for internal research, analytics and development. Professional advisers as described above; Service providers as described above; Our operating and other affiliated companies as described above; and Transaction (merger and acquisition) partners as described above. 
  1. What categories of Personal Information will you collect in the next 12 months and why? 

We will continue to collect the same categories of Personal Information listed in the chart above, for the same purposes. If this should change, we will issue an updated Privacy Notice. 

  1. Additional details about how we share your Personal Information 

To provide certain products and services, RAFIT may share information with third parties who provide services to us, such as the manufacturers, distributors, and operators of hardware and software used in our online dashboard and mobile application.  Any third party with whom we share identifiable information will only have access necessary to perform specific tasks on our behalf, will only use the information for this purpose, and will protect your information at least to the same extent that we do.  

RAFIT may share information to comply with our legal obligations, such as to respond to lawful requests and legal processes.  In the event we are asked to disclose your Personal Information, we will attempt to validate the request and inform you of it.  

Finally, RAFIT may disclose information where needed to affect the sale or transfer of its assets, enforce its rights, protect its property, or protect the rights, property, or safety of others, or as needed to support external auditing, compliance, and corporate governance functions.  

If RAFIT needs to share your information for a purpose not identified here, we will obtain your consent and disclose this purpose at the time of obtaining your consent.  For example, RAFIT may wish to use your information in demonstrations or other marketing materials and will contact you before doing so.  

  1. We do not knowingly collect the Personal Information of minors 

Our products and services are not directed to minors under the age of 18, and we do not knowingly collect or sell the Personal Information of minors. 

  1. How does RAFIT keep my information secure? 

We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards as outlined in the report issued by the California Attorney General in February 2016, available here. Specifically, among other safeguards, our reasonable security program implements and maintains all 20 of the Center for Internet Security’s Critical Security Controls for Effective Cyber Defense identified in Appendix A of the California Attorney General Report. As noted in that report, “there is no perfect security,” and reasonable security is a process that involves risk management rather than risk elimination. 

We are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, but no such program can be perfect. In other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits, or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from a failure on our part to implement and maintain reasonable security. 

  1. How long will RAFIT keep my information? 

We keep different kinds of information for different lengths of time, depending on the purpose for which it was processed and your specific situation.  Thus, we will retain information as long as necessary to accomplish the relevant purpose, but no longer.  

  1. Do we respond to “Do Not Track” signals? 

No, we do not respond to browser or do not track signals. 

  1. SMS Messaging –  

By checking the box to allow SMS messages and using the mobile application and RAFIT products, you grant us permission to notify you of important updates, login details, and other features of the RAFIT products. You may disable or opt out of these notifications at any time using the notification management section of the application or text STOP as a reply. 

This company will not share or sell the customer’s consent for SMS messages and phone numbers collected for SMS messages to any third parties under any circumstances 

  1. How do you access or request deletion of your Personal Information? 

You can do so by using the contact details set out at the end of this Privacy Notice. 

  1. What rights do you have in relation to the Personal Information we hold on you? 

Residents of certain states may have the following additional privacy rights. 

YOUR RIGHT TO REQUEST Disclosure OF INFORMATION WE COLLECT AND SHARE ABOUT YOU 

We are committed to ensuring that you know what information we collect about you. You can submit a request to us for the following information, with respect to Personal Information we have collected: 

  • The categories of Personal Information we’ve collected about you. 
  • The categories of sources from which we collected the Personal Information. 
  • The business or commercial purposes for which we collected or sold the Personal Information. 
  • The third parties with whom we shared the information. 
  • The specific pieces of information we collected. 

We are also committed to ensuring that you know what information we share about you. You can submit a request to us for the following further information: 

The categories of Personal Information that we have shared with service providers who provide services to us. 

Our responses to any of these requests will cover the 12-month period preceding our receipt of the request. 

YOUR RIGHT TO REQUEST THE DELETION OF PERSONAL INFORMATION WE HAVE COLLECTED FROM YOU 

Upon your request, we will delete the Personal Information we have collected about you, except for situations where specific information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. 

WE ARE COMMITTED TO HONORING YOUR RIGHTS 

We are committed to providing Consumers control over their Personal Information. If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly. In particular, this means that Consumers who exercise their rights under this Notice will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than other Consumers. 

CALIFORNIA “SHINE THE LIGHT” CIVIL CODE SECTION 1798.83 

No information is shared with third parties for their own marketing purposes. 

  1. For people who do business with us on behalf of their employer or contractor 

If you have provided your Personal Information to RAFIT when communicating or transacting with us on behalf of your employer or another business, you can always contact us at the details set forth below. We do not sell your Personal Information to third parties. 

If you exercise any of your privacy rights as an individual who does business with us on behalf of your employer or contractor, RAFIT will not discriminate against you for doing so and will continue to treat you fairly in our subsequent interactions with you. 

  1. How can you make a request to exercise your rights? 

To exercise any of the rights above, please contact us, by postal mail at: 

Legal Department 

POBox 42174 

Des Moines, Iowa 50323

USA 

by calling from within the United States: (515) 710-2626 

by webform: 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request