Privacy Policy

Effective Date: October 18, 2021

The rights of California residents under this Policy are described in Section 11.

Rubicon Holdings, LLC (“Rubicon”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Policy”). Rubicon collects information about you when you use our mobile applications, websites, and other products and services (collectively, the “Services”) and through other interactions and communications you have with us.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT USE OUR SERVICES.

1. SCOPE AND APPLICATION

This Policy applies to persons who use our Services to schedule pickups of waste and recyclable materials by independent haulers identified by Rubicon or (except as excluded elsewhere in this Policy) otherwise interact with Rubicon through the Services, such as by visiting our websites or mobile applications (“Users”). For purposes of this Policy, “personal information” includes your name, postal address, email address, telephone number and any other information that may be used to identify, contact or locate you or is reasonably capable of being associated with you. This Policy does not apply to: (i) information we collect from or about the third party, independent hauling companies that are (or will be) under contract with Rubicon (collectively, “Haulers”); or (ii) information collected by any third party for that third party’s own purposes, including any content that may link to or be accessible through our Services. If you interact with the Services as both a User and a Hauler, the respective Policies apply to your different interactions.

2. UPDATES TO THE POLICY

We may update this Policy from time to time. If we make significant changes in the way we treat your personal information we will provide you with notice through the Services or by some other means, such as email or posting a revised version of the Policy on our website. We encourage you to periodically review the Policy for the latest information on our privacy practices.

3. SOURCES OF PERSONAL INFORMATION

A. INFORMATION YOU PROVIDE TO US

We collect information from you when you directly provide it to us, for example when you register and create or modify your account, request certain services, contact customer support or provide feedback, or otherwise communicate with us.

B. INFORMATION WE AUTOMATICALLY COLLECT

When you use our Services, we may automatically collect information about you.

• Location Information: When you use the Services to schedule a pickup, we may collect precise location data about the pickup location from your mobile device. Depending on your settings on your mobile device, we may collect this information when the app is running in the foreground or background. You may choose to refuse to give Rubicon permission to collect your location information in your mobile device’s settings; however if you choose to do so, your use of the Services may be impaired. We may also derive your approximate location from your IP address. Refusing Rubicon permission to collect your location information will not prevent us from deriving your approximate location from your IP address.
  • Transaction Information: We collect transaction details related to your use of our Services, including the type of pickup requested, date and time the pickup was provided, amount charged, weight and substance of the pickup, and other related transaction details.
  • Usage and Preference Information: We may automatically collect information about how you interact with our Services, your preferences, and settings. In some cases, we do this through the use of cookies, beacons, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see the Section below regarding Cookies.
  • Device Information: We may automatically collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, unique device identifier, advertising identifiers, device motion information, and mobile network information.
  • Call and SMS Data: We may be required to call or text (SMS) you during your use of the Services. In connection with doing so, we receive call data, including the date and time of the call or SMS message, your phone numbers, and the content of the SMS message.
  • Log Information: When you interact with the Services, we automatically collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services, if you are linking to our Services from such third-party site or service.

C. IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Rubicon app wants permission to access certain types of data and will ask you to either consent or not consent to that request. Android devices will notify you of the permissions that the Rubicon app seeks before you first use the app, and your use of the app constitutes your consent.

D. INFORMATION WE COLLECT FROM OTHER SOURCES

We may also receive information from other sources and combine that with information we collect through our Services. For example:

• If you choose to link, create, or log in to your Rubicon account with a payment provider or social media platform, we may receive information about you or your connections from that site or app.
  • If you also interact with our Services in another capacity, for instance as a Hauler or user of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User.

4. OUR USE OF YOUR INFORMATION

We may use the information we collect about you to:

• Provide, maintain, and improve our Services
• Personalize and improve the Services, including providing or recommending features, content, and advertisements
• Facilitate pickups between you and a Hauler, including providing estimated times of arrival
• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Rubicon and third parties, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards
• Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends
• Respond to your inquiries and for other customer service purposes

5. SHARING OF INFORMATION

We may share any of the categories of personal information that we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

1. THROUGH OUR SERVICES

We may share your personal information:

• With Haulers to enable them to provide the Services you request. For example, we share your name and pickup location with Haulers. We will not share information with Haulers other than as necessary for them to perform the Services for you
  • With other people if directed by you
  • With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us
  • With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public
  • With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate
  • With your employer, if you request the Services on behalf of your employer

• OTHER SHARING

We may share your personal information:

• With Rubicon subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes
• With third party service providers such as vendors, consultants, and marketing partners, who need access to such information to carry out work on our behalf
• In an aggregated and/or anonymized form which cannot reasonably be used to identify you
• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or otherwise required by, any applicable law, regulation, or legal process
• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our Terms of Use, or any other policies, or to protect the rights, property, or safety of Rubicon or others
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company
• If we otherwise notify you and you consent to the sharing

6. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We may allow third parties to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services.

7. COOKIES

We and certain third parties may use cookies and other identification technologies on our Services. A cookie is a small file stored on your browser or device that may vary depending on the party serving the cookie. It may be possible to refuse to accept mobile cookies by activating the appropriate settings on your mobile device or downloading certain apps that block cookies. However, cookies are an important part of our Service; therefore you should be aware that if you choose to refuse cookies, this may affect the availability and functionality of the Services.

We use Google Analytics, a web analysis service provided by Google, to better understand your use of the Services and how we can improve them.  Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website.  Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other directly identifying information.  We do not combine the information collected through the use of Google Analytics with your personal information.  Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google.  Google Analytics uses its cookie(s) and the information Google Analytics collects to track your online activities over time and across different websites when you use our Services, and other websites.  Google’s ability to use and share information collected by Google Analytics about your visits to the Services is governed by the Google Analytics Terms of Service and the Google Privacy Policy.  Google uses the data collected to track and examine the use of the Website, to prepare reports on its activities, and share them with other Google services.  To more fully understand how Google may use the data it collects through the Services, please review “How Google Uses Information From Sites or Apps That Use Our Services” (located here).

8. SOCIAL MEDIA FEATURES

The Services may integrate with certain social media platforms which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such platforms enables the sharing of information with your friends or the public, depending on your settings with the applicable social media platform. Please refer to the privacy policies of those social media platforms for more information about how they share the data you provide to or share through them.

9. ACCOUNT INFORMATION

You may update or correct information about yourself at any time by logging into your in-app account. If you wish to cancel your account, please delete our app and email us at support@rubicon.com. In some cases, we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.

10. PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional messages from us by following the instructions in those messages. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.  If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

11. YOUR CALIFORNIA PRIVACY RIGHTS

This section provides the information required to be disclosed, and the rights California residents have, under the California Consumer Privacy Act (CCPA).  The CCPA currently exempts personal information reflecting a business-to-business communication (“B2B Personal Information”) from certain of the law’s requirements, and also currently exempts personal information collected and used about a natural person acting as a business’s employee or contractor (“Personnel Information”). The rights described below may not apply to B2B Personal Information or Personnel Information.

The information that we have collected and disclosed (as described above) in the past 12 months is along the following categories for the purposes of the CCPA:

We do not sell your personal information, and we do not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.

Under CCPA, California residents have the following rights with respect to their personal information:

• The right to receive information about the categories of personal information we have collected about you, the categories of sources we have received it from, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we have shared personal information, and the specific pieces of information we have collected about you.

• The right to obligate us to delete the personal information we have collected about you excluding that collected in a limited set of circumstances, such as personal information processed to complete a transaction and retention of personal information necessary for legal compliance.

• The right to opt out of the sale of your personal information.  Please note, however, that we do not sell your personal information. 

• The right not to be discriminated against for exercising any of the preceding rights.

You may exercise the rights above by submitting a request to compliance@rubicon.com or by telephone at (844) 479-1507.  In your request, please attest to the fact that you are a California resident and provide a current California address for your response. We may also need to collect additional information about your previous interactions with Rubicon to verify and fulfill your request. Please allow up to forty-five (45) days for the completion of your request.

You may authorize an agent to make a CCPA request on your behalf.  We will seek to verify your identity and your agent’s authority when we receive an individual rights request made on your behalf to ensure the security of your personal information, and may need to collect additional personal information to do so, e.g., by requesting documents showing your agent’s authority (such as powers of attorney).

We will not discriminate against you for exercising any of these data rights. To the greatest extent possible, we will provide you with the same quality of service at the same price after exercising these rights. 

12. Other Data Protection Rights

Depending on the jurisdiction in which you reside, and subject to applicable data protection laws, you may have the following data protection rights:  to access; correct; update; port; delete; restrict; or object to our processing of your personal information. We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. Please send such requests to compliance@rubicon.com. We may ask you to verify your identity in order to help us respond efficiently to your request.

13. Using the Services from Outside of the United States

If you are using the Services from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. For example, we and our customers and partners strive to take commercially reasonably efforts to put in place appropriate safeguards or identify an applicable derogation required for affecting the data transfer.

14. Residents of the European Economic Area (EEA), United Kingdom (UK), and Switzerland

This portion of our Policy applies to Users in the EEA, Switzerland and the United Kingdom only and applies to the extent of any inconsistency with the information above. All terms not otherwise defined in this section shall have the meanings as defined under applicable data protection laws.

Consent. We will make it clear if we rely on your consent to process your personal data and, where we rely on consent as a basis for processing personal data, you are free to withdraw your consent at any time.  If you wish to do so, please contact us at compliance@rubicon.com.

Legitimate Interest. Another reason we might use your personal data is because we have—or a third party has—a legitimate interest in doing so.  We do so when responding to your inquiries about our products and services; to provide services and technical support to you; and to enable internal administrative processes, such as account administration.

Retention Period. When we no longer need to process your personal data for the purposes described in this Policy, we will delete your personal data from our systems.  We therefore generally retain information when we have an ongoing legitimate business need for the information and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Providing Your Data. One reason we might use your personal data is because you’ve inquired into entering into a contract with us or your organization has entered into a contract with us and we need to provide services under that contract.  We may not be able to fulfill that contract if you choose not to provide us with your personal data.

Purpose of Processing. When we process your personal data, we determine the purpose of the processing and act as a controller.  We will primarily process personal data to offer our products services, process payments, and to provide prospective customers with information about our products, in addition to other purposes set out in this Policy.

Automated Decision Making. We do not engage in any automated decision making as a part of our Services.

Rectification. We want our records to be as accurate as possible, so please advise us of any errors and we will make corrections accordingly.  A difference of opinion or view does not necessarily mean that personal data is inaccurate.  If you have a difference of opinion, we will do our best to add that opinion to our records.

Erasure and your “Right to be Forgotten”. Please contact us at compliance@rubicon.com if you want us to delete your personal data.  We will do our best to honor your request, but we may have an obligation to keep records for audit and legal purposes. We may also be able to “Restrict Processing” or delete specific information or a document, which we will do without undue delay, for example, where it has been sent to us in error.

Object to Processing. In certain circumstances, you may have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing or for our or a third party’s legitimate interests. Please contact us at compliance@rubicon.com if you would like us to do so.

Right to Restrict Processing. Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.”  Simply a difference of opinion or view does not necessarily justify a restriction, but we will always consider your opinion.  We will always inform you before we lift any restriction.

Access Data. You may, subject to certain exceptions, receive a copy of your personal data from us. If you would like to do so, please contact us at compliance@rubicon.com and we will advise you of the next steps as soon as possible.

Data Portability. At your request, we are happy to provide your personal data in a machine-readable or “portable” format so you can move it or store it wherever you want, subject to certain limitations.  We can also send it to another controller where technically feasible. If you would like to do so, please contact us at compliance@rubicon.com and we will advise you of the next steps.

Right to Complain. If you have a complaint about how Rubicon uses your personal data, we hope that in the first instance you will contact us and we will promptly address your concern.  However, you can always file a complaint with the supervisory authority in your jurisdiction.  For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA are available at https://edpb.europa.eu/about-edpb/board/members_en; and contact details for the data protection authority in the UK are available at https://ico.org.uk/).

Charges/Fees. We do not charge you a fee for exercising any of your rights described above.

15. Linked Websites

Some hyperlinks may be posted on the Services that link to other websites not under our control. We are not responsible for, and this Policy does not apply to, the privacy practices of those websites. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our Services links to, even if you reached that website through the Services, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal information that is collected about you is used and protected.

16. CHILDREN’S PRIVACY

Users must be at least 18 years of age, or the age of legal majority in their jurisdiction (if different than 18) to download and use our Services. We do not collect any information regarding children under the age of 16. If we learn that we have collected or received personal information from a child under the age of 16, we will delete that information. If you believe that we might have any information from or about a child under 16, please contact us using the contact information at the end of this Policy. 

17. CONTACT US

If you or your agent have any questions about this Policy, please contact us at (844) 479-1507.