Privacy Policy

1. INTRODUCTION

We are rTurner Consulting, LLC (“Company,” “we,” “us,” “our”), a company registered in the Commonwealth of Virginia, United States.

This User Privacy Policy (“Privacy Policy”, “Privacy Terms” or “Terms”) governs and explains how rTurner Consulting, LLC (rTC) and related entities (“rTC” or “we”) collect, disclose, and use personal information as we provide a Covered Service.

As of the date of these Terms, our Covered Services include:

rTC has an agreement to provide a Covered Service to one of its customers (the “Agreement”). For purposes of these Privacy Terms, we refer to anyone who is allowed to use a Covered Service under the Agreement as a “User.”

2. FROM WHOM DO WE COLLECT PERSONAL INFORMATION

Under these Terms, we collect personal information from Users.

3. PERSONAL INFORMATION WE COLLECT

A Covered Service may collect the following categories of personal information.

Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from Users, their devices, and third parties.
Contact information such as name, address, and telephone number. This category of information is collected from Users, their devices, or other third parties such as our business partners.
Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a consumer’s interaction with a website, application, or advertisement. This category of information is collected from Users and their devices.
Geolocation data. This category of information is collected from Users and their devices.
Sensory data, including electronic, visual, or similar information. Users may choose to upload a photo as part of their profile.

Inferences, such as a profile about a User’s preferences, characteristics, and behavior, drawn from information we collect from the User and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.

4. HOW WE COLLECT PERSONAL INFORMATION

We Collect Information Users Provide to Us. We collect personal information that Users provide to us, depending on how they interact with us. For example, Users may provide personal information to us when they:

Sign up to receive communications, participate in events, access a Covered Service, or otherwise communicate with us under the Agreement. For example, Users may provide information such as name, email address, physical address, phone number, employment information, and mobile phone number.
Order or purchase features of a Covered Service (such as a Market Detail report).
Share product feedback or submit requests for information.

We may also collect information when Users share experiences, suggestions, preferences or other input (e.g., expressing preferences, comments, complaints, etc.), or submit requests for information from us.

We Collect Information Automatically or From Others. We may obtain some personal information automatically when Users access or use the Covered Service. For example:

Traffic Data. A Covered Service may automatically track and collect IP address, domain server, type of computer or device, and type of web browser. This helps us customize a User’s experience, provide security features, and assists with our marketing.
Cookies and Related Technology. We may also use cookies, web beacons, and related technologies (“Cookies”). These technologies are generally small bits of code embedded in pages or images that allow us to remember information about a User’s interactions with us. For example, the Cookies may help us remember a User’s language or browser settings and understand how you have interacted with the product or service under this Agreement. We use these technologies to improve a User’s experience with the Covered Service and to improve our communications. Users may adjust browser settings or our Cookie banner to accept or not accept certain cookies.
Third Party Providers and Business Partners. We may also collect personal information from a Customer about its Users (for example, the contact information for Users). We may also collect personal information from third-party providers and business partners, including business partners, public databases, social media platforms, or third parties such as analytics or advertising and marketing providers, where permitted under applicable law.

Information collected automatically or from others may be combined with other personal information we have about Users so that we can improve and customize our products, services, and communications.

5. HOW WE USE PERSONAL INFORMATION

We use the personal information we collect, on its own and combined with other information we collect about Users, for the following purposes:

Fulfilling the purpose of the Agreement.
Providing the Covered Service.
Communicating with you and Users (such as about products, services, events, promotions and other offers and responding to your inquiries, comments, feedback, stories, or postings).
Users can unsubscribe from our email marketing communications at any time.
Customizing and improving the User experience or Covered Service.
Fraud detection, security, legal enforcement and compliance. We use information collected by the Covered Service to protect the security and integrity of the Covered Service, for enforcement of our Agreement, and to satisfy rTC’s legal obligations.

Overall, rTC will use personal information with consent of the User, to perform the Agreement, or where the processing is in rTC’s legitimate interests and not overridden by the User’s data protection interests or fundamental rights and freedoms. In some cases, rTC may also have a legal obligation to process personal information or may need to do so to exercise, establish, or defend legal claims.

6. HOW WE DISCLOSE PERSONAL INFORMATION COLLECTED BY A COVERED SERVICE

We may disclose personal information collected under these Terms within rTC and to third parties for the purposes described in “5. How We Use Personal Information”, or with a User’s consent. We may disclose personal information to the following types of third parties:

To other Users of a Covered Service. Some Covered Services may allow Users to share their personal information with other Users or entities who also use the same Covered Service. Users are responsible for deciding whether to engage in this data sharing and what elements of their personal information would be shared. For example, Users may choose to share their name, company affiliation, and title only or may also choose to share their email and phone.
Within rTC to our related corporate entities. We may disclose personal information within rTC and to our related entities to provide our products, services, promotions, and other Services to you and for our marketing purposes, in accordance with applicable law.
Service providers. We may disclose personal information to third-party service providers that provide a variety of services on our behalf, including but not limited to the development, maintenance, and support of the Covered Service, the distribution of email and mobile messages, promotions, advertising services, and marketing research and analysis.
Other entities. In addition, we may disclose personal information with other entities for additional purposes. For example, we may share personal information with our business partners and other third parties for joint marketing purposes, at a User’s request, or as otherwise needed to perform the Agreement.  We may also share personal information as part of a sale, merger or change in control, or in preparation for these corporate events. An entity that buys us or part of our business may continue to use personal information collected under these Terms in accordance with these Terms.
We may also disclose the personal information we collect to our analytics and advertising vendors and partners to develop analysis and business intelligence for our advertising and marketing purposes.
We may also share personal information as may be necessary to protect the safety, property, or other rights of rTC or related entities, and their respective employees, customers, visitors, users, service providers, or any other person or entity; to comply with law, a court order, or other legal process (which may include access by courts, law enforcement or governmental authorities in the US or other jurisdictions), or in connection with a legal investigation; to enforce any applicable terms and conditions and other agreements; as otherwise may be required or permitted by applicable law; or in accordance with your consent.

Is Your Information Transferred Internationally? Our servers are located in the USA, yet we may transfer, store, and process your information in countries other than your own.

If you are accessing our Services from outside, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

7. Access to Information and User Choices

We provide Users with the opportunity to access, update or delete certain information and to unsubscribe or opt-out from certain communications. For example, you may exercise your choices as described below. Please be aware that, if a User does not allow us to collect and use their personal information, we may not be able to deliver the Covered Service or fulfill the Agreement.

Opportunity to access, update and delete personal information. Users may request to access, delete, or update their personal information by emailing support@fedpipeline.com or support@rturner.net.

Please be aware that a User’s right to request access, deletion, or update of their personal information may be limited by applicable exceptions such as rTC’s obligation to perform an ongoing contract with you or to satisfy rTC’s own legal compliance obligations.

Communications Preferences. Users may choose how and whether to receive promotional or marketing communications from us. At any time, they can manage their communication preferences via the Email Preference Center or may unsubscribe from receiving such communications by utilizing the “unsubscribe” or opt-out feature within the communication.

Requests to unsubscribe from rTC communications may also be made by contacting rTC via the methods indicated in “Contact Us.” Because we plan our communications in advance, it may take up to 5 business days for your “unsubscribe” request to become effective.

If you continue to receive our communications after submitting an “unsubscribe” request, please let us know by contacting us using one of the methods listed in the “Contact Us” Section so that we can investigate the situation. Please note that we may continue to send transactional or service-related messages to Users and that Users may not submit unsubscribe requests on behalf of someone else.

8. Information Security

We seek to keep personal information secure by implementing reasonable technical, administrative, and physical safeguards to help us protect such information from unauthorized access, use, and disclosure. We also ask our third-party service providers to use reasonable security measures to protect your information from unauthorized access, use and disclosure. However, please be aware that no method of electronically transmitting or storing information is ever completely secure. 

9. Retention

We retain personal information for the length of time needed to carry out the processing  purposes described in these Terms. We also retain information for related business purposes, security, legal compliance, and disputes and claims handling, consistent with our retention policy and as permitted by applicable law.

10. User Privacy Rights

Users may have a variety of privacy rights including:

The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
The right to correct inaccurate personal information that we have collected about them.
The right to delete personal information that we have collected about them, subject to certain exceptions. For example, we may not be able to delete a User’s information when you have a contract with us or they are actively engaged with rTC on a product support issue.
The right to opt out. Users have the right to opt out of the disclosure of personal information to third parties for monetary or other valuable consideration.
The right not to receive discriminatory treatment for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of their rights.
rTC will not discriminate against a User for exercising their privacy rights.

What Happens When a User Exercises Their Rights. As required under applicable law, we will take steps to verify the User’s identity before acting on a request to exercise their rights. We may require Users to provide their first name, last name, email address, and other information to verify their identity. We may limit our response to their exercise of the above rights as permitted under applicable law. When a User submits a request to exercise the rights above, we will use the information they provide to process their request and to maintain a record of their request and our response, as permitted under applicable law.

Under applicable law, Users may designate an authorized agent to make a request on their behalf. They may make such a designation by providing the agent with written permission to act on their behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require Users to verify their own identity in response to a request, even if they choose to use an agent. 

11. Contact Us

If you have any questions about these Privacy Terms, please contact us via email on  privacy@rturner.net or support@fedpipeline.com.

Users may Contact Us via telephone on +1 (202) 480-9706.

Written requests or notifications may be sent to:

rTurner Consulting, LLC
P.O. Box 1058
Taylorsville, KY 40071 USA

12. Updates and Amendments.

We may update these Privacy Terms from time to time, and the updated Privacy Terms apply to after the effective date stated in the revised Privacy Terms. If we change the policy in a material way, we will provide appropriate notice to our Users.