Privacy Policy

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This Privacy Policy (this "Policy") describes the categories of personal information that 21 in Right Inc. ("21 in Right," "we," "us," or "our") collects through this landing page and any associated web form (collectively, the "Site"), the purposes for which that information is processed, the parties to whom it is disclosed, and the rights available to individuals with respect to it.

This Policy is issued as a notice at collection within the meaning of California Civil Code section 1798.100(a) and title 11, section 7012 of the California Code of Regulations, and as the privacy notice required by the comprehensive consumer data protection statutes of the several states identified in Section 9.1. It is intended to be read as a complete statement of our practices with respect to information submitted through the Site.

Notice of marketing use. An email address submitted through the Site will be used to send commercial electronic mail messages, including marketing campaigns, and may be disclosed to advertising platforms for the purpose of targeted advertising. Section 6 governs. An individual who does not wish to receive such messages should not submit an email address through the Site, or should exercise the withdrawal rights described in Section 6.4.

1. Scope and Application

1.1 Covered processing

This Policy applies to personal information we collect through the Site, whether submitted directly by an individual or collected automatically by technical means. It does not apply to information collected offline, through channels other than the Site, or by third parties whose services are linked from the Site and whose practices are governed by their own notices.

1.2 Territorial scope

The Site is directed to individuals located in the United States. We do not offer goods or services to, and do not monitor the behavior of, data subjects located in the European Economic Area, the United Kingdom, or Switzerland, and we do not intend this Site to constitute an offering within the meaning of Article 3(2) of Regulation (EU) 2016/679. Individuals located outside the United States should not submit information through the Site.

1.3 Order of precedence

Where a separate written agreement between an individual and 21 in Right addresses the processing of that individual’s personal information, that agreement controls to the extent of any conflict with this Policy.

1.4 Acceptance

Submission of information through the Site constitutes acknowledgment of this Policy. Acknowledgment is not a substitute for consent where consent is separately required by law, and we do not treat it as such.

2. Definitions

Capitalized and quoted terms used in this Policy have the meanings assigned below. Terms defined by statute carry their statutory meaning within the jurisdiction imposing the definition.

2.1 "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 individual or household, consistent with California Civil Code section 1798.140(v). In states using the term "personal data," that term is treated as coextensive for purposes of this Policy.

2.2 "Sale" and "share" have the meanings given in California Civil Code section 1798.140(ad) and (ah), respectively, and include the disclosure of personal information to a third party for monetary or other valuable consideration and the disclosure of personal information for cross-context behavioral advertising.

2.3 "Targeted advertising" means the display of advertisements selected on the basis of personal information obtained from an individual’s activities over time and across nonaffiliated websites or online applications, as that term is used in the Virginia Consumer Data Protection Act and its analogues.

2.4 "Service provider" and "processor" mean a person that processes personal information on our behalf pursuant to a written contract satisfying the requirements of the applicable statute.

2.5 "Commercial electronic mail message" has the meaning given in 15 U.S.C. section 7702(2).

3. Identity of the Controlling Entity

21 in Right is the "business" for purposes of the California Consumer Privacy Act and the "controller" for purposes of the comprehensive privacy statutes of other states. Our legal name, registered address, and contact particulars are set out in Section 14.

4. Categories of Personal Information Collected

4.1 Categories, sources, and purposes

The table below states each category of personal information we collect through the Site, by reference to the statutory categories enumerated at California Civil Code section 1798.140(v)(1).

4.2 Sensitive personal information

We do not collect, and do not request through the Site, sensitive personal information within the meaning of California Civil Code section 1798.140(ae) or sensitive data within the meaning of the analogous provisions of other state statutes. This includes government identifiers, financial account credentials, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, health information, sexual orientation, biometric identifiers, and the contents of communications not directed to us. We do not use or disclose any such information for purposes requiring the right to limit under California Civil Code section 1798.121.

4.3 Consequences of nondisclosure

Provision of an email address is a condition of receiving the materials or communications offered through the Site. All other fields are optional, and declining to complete them will not prevent fulfillment of the request.

5. Purposes of Processing

5.1 Business purposes

We process personal information for the following business purposes within the meaning of California Civil Code section 1798.140(e): responding to inquiries and fulfilling requests; performing services on our own behalf, including customer service, order fulfillment, and account maintenance; auditing interactions with the Site; detecting and preventing security incidents, fraud, and malicious or deceptive activity; debugging and repairing errors; internal research and quality assurance; and compliance with legal obligations.

5.2 Commercial purposes

We process personal information, and in particular email addresses, for the commercial purposes of advertising and marketing our products and services. This includes the activities enumerated in Section 6.

5.3 Limitation

We do not process personal information collected through the Site for purposes that are neither compatible with, nor reasonably necessary and proportionate to, the purposes disclosed in this Section, without providing notice consistent with Section 13.

6. Commercial Electronic Mail and Marketing

6.1 Marketing use of email addresses

An email address submitted through the Site will be added to our marketing distribution lists and marketing automation systems and may be used to transmit commercial electronic mail messages, including but not limited to newsletters, promotional offers, discounts, product and feature announcements, event and webinar invitations, re-engagement campaigns, abandoned-inquiry follow-up, and other marketing campaigns concerning our products and services and those of our affiliates.

6.2 Advertising platform disclosure

We may transmit email addresses, in cryptographically hashed form, to third-party advertising platforms for the purposes of (i) matching the address against an existing platform account so that our advertisements may be displayed to that account, (ii) constructing similar or lookalike audiences, and (iii) suppressing advertisements from individuals who have already converted. Such transmission constitutes a sale or share, or the processing of personal data for targeted advertising, under the statutes identified in Section 9.1. We make this disclosure affirmatively, and we do not represent that we abstain from such activity.

6.3 Basis for transmission

Submission of an email address through a form that discloses, at or before the point of collection, that marketing messages will follow constitutes consent to receive those messages for purposes of the CAN-SPAM Act, 15 U.S.C. sections 7701 through 7713. Consent obtained in this manner is revocable at will and does not survive revocation.

6.4 Withdrawal

Every commercial electronic mail message we transmit contains a functioning unsubscribe mechanism, which will remain operable for not less than thirty days after transmission, as required by 15 U.S.C. section 7704(a)(3)(A). A withdrawal request may also be submitted to the address in Section 14. We will give effect to a withdrawal request not later than ten business days after receipt, consistent with 15 U.S.C. section 7704(a)(4)(A). Withdrawal is not conditioned on the payment of a fee, the provision of information beyond an email address, or the completion of any step other than sending a reply or visiting a single web page.

6.5 Suppression records

Upon withdrawal, we retain the withdrawing individual’s email address, in hashed or plain form, on a suppression list for the sole purpose of ensuring that no further commercial electronic mail message is transmitted to that address. Retention for this purpose is necessary to comply with a legal obligation and is accordingly excepted from deletion under California Civil Code section 1798.105(d)(8) and the corresponding provisions of other state statutes. A request to delete personal information will therefore not result in removal from the suppression list, and we will so advise the requesting individual.

6.6 Transactional and relationship messages

Withdrawal of marketing consent does not affect our transmission of transactional or relationship messages within the meaning of 15 U.S.C. section 7702(17), including responses to inquiries, notices of changes to this Policy, and communications regarding a transaction the individual has entered into.

6.7 Telephone and text message communications

Where a telephone number is voluntarily supplied, we will not use that number to place autodialed or prerecorded telemarketing calls, or to transmit marketing text messages, in the absence of prior express written consent obtained separately and satisfying 47 C.F.R. section 64.1200(f)(9).

7. Disclosure to Third Parties

7.1 Service providers and processors

We disclose personal information to vendors that perform services on our behalf, including email service providers, marketing automation and customer relationship management platforms, web hosting and content delivery providers, analytics providers, and form and lead-capture providers. Each such vendor is engaged under a written contract that limits processing to the purposes specified by us, prohibits retention, use, or disclosure for any other purpose, and prohibits the combination of our data with data obtained from other sources except as permitted by law.

7.2 Advertising platforms

We disclose personal information to advertising platforms as described in Section 6.2. Such platforms may act as third parties rather than service providers, and their processing is governed by their own notices.

7.3 Legal and protective disclosures

We disclose personal information where required by law, subpoena, court order, or other legal process, and where we determine in good faith that disclosure is necessary to investigate or prevent unlawful activity, to enforce our agreements, or to protect the rights, property, or safety of any person.

7.4 Corporate transactions

In connection with a merger, acquisition, reorganization, financing, receivership, assignment for the benefit of creditors, or sale of all or a substantial portion of our assets, personal information may be transferred as an asset of the business. Any acquirer will remain subject to the commitments in this Policy with respect to information acquired, unless and until affected individuals receive notice consistent with Section 13.

7.5 Minors

We do not have actual knowledge that we sell or share the personal information of consumers under sixteen years of age, and we do not knowingly do so.

8. Tracking Technologies and Opt-Out Preference Signals

8.1 Technologies employed

The Site uses cookies, pixel tags, web beacons, software development kits, and similar technologies, deployed by us and by our vendors, to operate the Site, to measure traffic, and to support the advertising activity described in Section 6.2.

8.2 Browser controls

Most browsers permit the refusal or deletion of cookies. Exercising those controls may impair the operation of portions of the Site.

8.3 Opt-out preference signals

We process opt-out preference signals, including the Global Privacy Control, in a frictionless manner as contemplated by title 11, section 7025 of the California Code of Regulations, and we treat such a signal as a valid request to opt out of the sale and sharing of personal information and of processing for targeted advertising. We also honor universal opt-out mechanisms recognized under the Colorado Privacy Act and its implementing rules, and under the analogous provisions of other state statutes. Where a signal is received from a browser that cannot be associated with a known individual, the opt-out is applied to that browser.

9. Individual Rights

9.1 Applicable statutes

The rights described in this Section arise under the California Consumer Privacy Act, California Civil Code sections 1798.100 through 1798.199.100, as amended; the Virginia Consumer Data Protection Act, Virginia Code Annotated section 59.1-575 et seq.; the Colorado Privacy Act, Colorado Revised Statutes section 6-1-1301 et seq.; the Connecticut Data Privacy Act, Connecticut General Statutes section 42-515 et seq.; the Utah Consumer Privacy Act, Utah Code Annotated section 13-61-101 et seq.; the Texas Data Privacy and Security Act, Texas Business and Commerce Code chapter 541; and the comprehensive consumer privacy statutes of the additional states that have enacted them, including Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island. We extend the rights below to all individuals who submit information through the Site, without regard to residency, except where a right is by its terms available only to residents of a particular state.

9.2 Enumerated rights

Subject to the exceptions provided by the applicable statute, an individual may:

• confirm whether we process personal information concerning that individual and obtain access to it, together with the categories of information, sources, purposes, and recipients
• obtain a copy of that information in a portable and, to the extent technically feasible, readily usable format
• require correction of inaccurate personal information, taking into account its nature and the purposes of processing
• require deletion of personal information, subject to the exceptions enumerated in the applicable statute and to Section 6.5 of this Policy
• opt out of the sale or sharing of personal information and of processing for targeted advertising; and
• be free from unlawful discrimination for exercising any of the foregoing rights.

9.3 Method of submission

Requests may be submitted by electronic mail to info@21inright.com, or by the "Do Not Sell or Share My Personal Information" link maintained in the footer of the Site in the case of an opt-out request. We provide at least two designated methods for submitting requests where the applicable statute so requires.

9.4 Verification

Before giving effect to a request to know, correct, or delete, we will take reasonable steps to verify the identity of the requesting individual to a degree of certainty commensurate with the sensitivity of the information and the risk of harm from unauthorized disclosure. Verification will ordinarily consist of confirming control of the email address associated with the record. We will not require the creation of an account as a condition of submitting a request. A request to opt out is not subject to verification.

9.5 Authorized agents

An authorized agent may submit a request on an individual’s behalf upon provision of written authorization signed by the individual, or a power of attorney executed under the applicable state’s Probate Code. We may require the individual to verify their own identity directly with us and to confirm that the agent is authorized.

9.6 Timing

We will acknowledge receipt of a request within ten business days and will respond substantively within forty-five calendar days of receipt. Where reasonably necessary, and upon notice to the individual within the initial period, we may extend the response period by a further forty-five calendar days. Opt-out requests will be given effect within fifteen business days of receipt.

9.7 Appeals

An individual whose request is refused, in whole or in part, may appeal that decision by writing to info@21inright.com with the subject line "Privacy Request Appeal" within a reasonable period after receipt of our decision. We will review the appeal and inform the individual in writing of the outcome, together with a written explanation of the reasons, within forty-five calendar days of receipt. If the appeal is denied, we will provide a method by which the individual may contact the Attorney General of their state to submit a complaint.

9.8 Nondiscrimination

We will not deny goods or services, charge a different price or rate, provide a different level or quality of goods or services, or suggest that we will do any of the foregoing, on the basis of an individual’s exercise of a right under this Section. We do not offer financial incentives in exchange for the retention or sale of personal information.

9.9 California "Shine the Light." California residents may request, once per calendar year, information regarding our disclosure of personal information to third parties for those parties’ direct marketing purposes, pursuant to California Civil Code section 1798.83. Requests should be directed to the address in Section 14.

9.10 Nevada

Nevada residents may submit a verified request directing us not to make any sale of covered information as defined in Nevada Revised Statutes section 603A.320. Requests should be directed to the address in Section 14.

10. Retention

10.1 We retain each category of personal information for the period reasonably necessary to accomplish the purposes disclosed in Section 5, and thereafter only as required to comply with a legal obligation, resolve a dispute, or enforce an agreement.

10.2 In the ordinary course, and absent an applicable exception, we apply the following criteria: marketing contact records are retained for so long as the individual remains subscribed and for a period of 24 months following the last engagement, after which the record is deleted or deidentified; inquiry and correspondence records are retained for 36 months from the date of last correspondence; technical log data is retained for 14 months; and suppression records are retained indefinitely for the reason stated in Section 6.5.

11. Information Security and Incident Notification

11.1 We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, use, modification, or disclosure, and reasonably appropriate to the nature of the information and the risks presented by its processing.

11.2 No safeguard is impenetrable, and we make no representation or warranty that unauthorized access will not occur. Nothing in this Section constitutes a guarantee of security or an assumption of liability beyond that imposed by applicable law.

11.3 In the event of a breach of the security of the system involving personal information, we will provide notification to affected individuals and to regulatory authorities in the manner and within the time required by the applicable state breach notification statute.

12. Children’s Information

12.1 The Site is a general audience property and is not directed to children under thirteen years of age within the meaning of the Children’s Online Privacy Protection Act, 15 U.S.C. sections 6501 through 6506, and its implementing regulations at 16 C.F.R. part 312. We do not knowingly collect personal information from such children.

12.2 Upon learning that we have collected personal information from a child under thirteen without verifiable parental consent, we will delete that information promptly. A parent or guardian who believes that a child has provided information to us should contact us at the address in Section 14.

12.3 We do not knowingly process the personal data of a consumer between the ages of thirteen and sixteen for purposes of targeted advertising or sale without consent, as required by the applicable state statutes.

13. Amendment

13.1 We may amend this Policy from time to time. The effective date and version number appearing in the masthead will be revised accordingly, and prior versions will be retained and made available upon request.

13.2 Amendments apply prospectively

Where an amendment would materially expand the purposes for which personal information already collected is processed, we will provide advance notice by electronic mail to affected individuals and, where the applicable law so requires, will obtain consent before applying the amended terms to that information. We do not apply materially different terms retroactively to information collected under a prior version of this Policy.

14. Notices and Contact

Inquiries, requests, and appeals under this Policy should be addressed to:

The postal address stated above is the physical postal address included in our commercial electronic mail messages pursuant to 15 U.S.C. section 7704(a)(5)(A)(iii).

15. General Provisions

15.1 Governing law

This Policy and any dispute arising from it are governed by the laws of the State of Pennsylvania, without regard to its conflict of laws principles, except to the extent that the law of another jurisdiction governs by its own force.

15.2 Severability

If any provision of this Policy is held invalid or unenforceable, that provision shall be modified to the minimum extent necessary to render it enforceable, and the remaining provisions shall continue in full force.

15.3 Interpretation

Section headings are for convenience only and do not affect interpretation. The words "include" and "including" are not words of limitation. Where this Policy affords protection exceeding that required by a statute, the greater protection applies as a matter of contract and not as an admission that the statute so requires.

15.4 Accessibility

This Policy is maintained in a format that is reasonably accessible to individuals with disabilities, consistent with generally recognized industry standards.