Privacy Policy

Last updated: Feb 28, 2024

Welcome to the Platform, operated by Almanach Group LTD (“Almanach”). Together you and Almanach may be referred to as the Parties or separately as Party. Almanach (“we,” “our,” or “us”) is concerned about your privacy. We want to familiarize you with how we may collect, use, and disclose your information. This Privacy Policy describes our practices in connection with information which we collect through our Websites (www.richobo.eu, www.richobo.com, www.richobo.ru), communications (e.g., emails, phone calls, and texts), mobile applications and services (collectively, the “Platform”). By using our Platform, you agree and consent with all terms of this Privacy Policy. Please do not use our Platform if you disagree with any part of this document. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at the address listed below in the “Contact” section. Terms not defined in this Privacy Policy are defined in our Terms of Use, available at: www.Richobo.com/termsofuse.

1. INFORMATION WE COLLECT

We may collect, transmit, and store information about you in connection with your use of the Platform, including any information you send to us or through the Platform.

A. Account Information. When you create an account, we store and use the information you provide during that process, such as the first and last name you enter, email address, zip code, physical address, and any other information you may provide during the account creation process, such as a gender, phone number, or birth date. (together with other information with which you may be reasonably identified, “Personal Information”).

B. Public Content. Your contributions to the Platform are intended for public consumption and are therefore viewable by the public, including your photos, ratings, reviews, tips, lists, compliments, and edits to business page information. Your account profile (e.g., first name, last initial, city, neighborhood, the month and year you created your account, profile photos) is also intended for public consumption, as is some of your other activity through the Platform. You can limit the public nature of some of these activities through your account settings. Other users may be able to identify you, or associate you with your account, if you include Personal Information in the content you post publicly. You can reduce the risk of being personally identified by using the Platform pseudonymously, though doing so could detract from the credibility of your contributions to the Platform. Please also note that the messages you send or receive using the Platform are only private to the extent that both you and the recipient(s) of your messages keep them private. For example, if you send a message to another user, that user may choose to publicly post it. We may access, review, and disclose such messages in connection with investigations related to use of the Platform, as well as our efforts to improve the Platform.

C. Communications. When you sign up for an account or use certain features, you are opting to receive messages from other users, businesses, and us. You can manage some of your messaging preferences through your account settings, but note that you cannot opt out of receiving certain administrative, transactional, or legal messages from us. We may also track your actions in response to the messages you receive from us or through the Platform, such as whether you deleted, opened, or forwarded such messages, and share that information with other parties to your messages (for example, to let them know if you have viewed their message). When a user requests a quote or similar information from multiple businesses through the Platform, we may disclose to those businesses information about the status of the user’s requests, such as whether any business has responded to the request, the type of response provided (for example, a quote or a request for more information), and whether the user has responded to any business’s reply. If you exchange messages with others through the Platform, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to use of the Platform, as well as our efforts to improve the Platform. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests to exchange reviews for compensation. If you send or receive messages through the Platform via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on the Platform, or use a phone number associated now or previously with such a business, we may contact you, including by phone or email, using the contact information you provide us, make publicly available, or that we have on record for your business. Our communications with you, including phone calls, may be monitored and recorded for quality purposes.

D. Transactions: If you initiate a transaction through the Platform, such as a reservation or purchase, we will collect and store information you provide associated with your transaction, such as your name, phone number, address, email, and payment information, as well as any other information you provide, in order to process your transaction, send communications about the transaction to you, and facilitate future transactions. This information may be shared with third parties, and third parties may share such information with us, for the same purposes. When you submit credit card numbers and other sensitive payment information, that information is encrypted using industry standard technology. If you write reviews about businesses with which you transact through the Platform, we may publicly display the fact that you transacted with those businesses in connection with such reviews.

E. Activity: We store information about your use of the Platform, such as your search activity, the pages you view, the date and time of your visits, businesses you contact using our mobile applications, and reservations, purchases, or transactions you make through the Platform. We also store information that your computer or mobile device may provide to us in connection with your use of the Platform, such as your browser type, type of computer or mobile device, browser language, IP address, WiFi information such as SSID, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs and mobile applications. We may also receive and store your location whenever our mobile applications are running, including when running in the background, if you enable our mobile apps to access such information in the course of using the Platform. You may be able to limit or disallow our use of certain location data through your device or browser settings, for example by adjusting the settings for our applications in iOS or Android privacy settings.

F. Different Devices: You may access the Platform through different devices (e.g., your mobile phone or personal computer) and different platforms. The information that we collect and store through those different uses may be cross-referenced and combined.

G. Professional Information: If you represent a business on the Platform, we may collect and display information about you related to your business activities, such as a business name that may incorporate your name, or a publicly available business address that is also used as a home address. We will also collect and display information about your professional background that you choose to share with us through the Platform.

H. Legal Basis for Processing (EEA). For European Residents, our legal basis for collecting and using the information described above will depend on the specific information concerned and the context in which we collect it. We, however, will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person (for instance, to prevent, investigate, or identify possible wrongdoing in connection with the Platform or to comply with legal obligations). If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Platform, communicate with you in relation to our Platforms, or for our other legitimate commercial interests, for instance, when responding to your queries, to analyze and improve our Platform, engage in marketing, or for the purposes of detecting or preventing fraud. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address listed below in the “Contact” section.

2. HOW WE USE INFORMATION WE COLLECT

A. Generally. We use the information we collect: to provide you with our Platform; to respond to your inquiries and fulfill your requests; to keep a record of your contact information and correspondence and use it to respond to you via e-mail or other means of communication; to send administrative information, for example information regarding the Platform and changes to our terms, conditions, and policies; for our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Platform, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities; as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

B. Your Consent. You acknowledge and agree that we may disclose your information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to: (a) comply with a current judicial proceeding, a court order or legal process served on us, (b) enforce this Agreement; (c) protect the rights, property or personal safety of our company, its members, agents, employees, users, and the public; or (d) enable the transfer or sale to another entity of all or substantially all assets in our line of business.

C. Cookies. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device. Cookies help us to improve the offered services and make use of our services more convenient. We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects, and similar technologies (“Cookies”) in connection with your use of the Platform, third party websites, and mobile applications. You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Platform. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings.

3. THIRD PARTIES

A. Advertisers. We allow third parties to use Cookies through the Platform to collect the same type of information for the same purposes as we do. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have access to or control over the Cookies they use. We may also share some non-identifiable, de-identified or aggregated information from or about you, such as location information, with third parties in connection with advertising programs and data analytics. You may be able to limit our sharing of some of this information through your mobile device settings, or through the Platform’s settings.

B. Content Partners. We allow third party partners to use and display some of the public content available through the Platform, such as your photos, reviews, and other public content.

C. Platform Providers. We rely on third party service providers to support or provide services for us in connection with your use of the Platform, such as technical and customer support, tracking and reporting usage of the Platform, quality assurance testing, payment processing, marketing, and other functions. We share information from or about you with these third party providers so that they can perform their services or complete your requests. You may be able to limit our access to some of this information through your mobile device settings, or through the Platform’s settings. Our third party service providers may likewise share information with us that they obtain from or about you in connection with providing their services or completing your requests.

D. Aggregate or Anonymous Information. We share user information in the aggregate with third parties, such as businesses that are listed on the Platform and content distributors. For example, we may disclose the number of users that have been exposed to or interacted with advertisements, or that we believe visited the physical location of a particular business.

E. Business Transfers. We share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, and require them to also honor this Privacy Policy. If another company acquires us, or all or substantially all our assets, that company will possess the same information, and will collect, use, and disclose the information only as described in this Privacy Policy.

F. Businesses. We may share information from or about you (such as your city, and if you provide it, your age and gender), your device type, and your use of the Platform (such as which businesses you bookmark or call, or if you visit a business’s URL) with businesses on the Platform. You may adjust your account settings to increase or decrease the amount of information we share. Keep in mind that businesses can also view your public activity and posts, and may receive information from or about you when you transact or communicate with them, through the Platform or otherwise, regardless of your settings.

G. Links. The Platform may link to third party-controlled websites, like a business’s URL. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices. H. Third Party Integrations. If you sign up for, or log into, the Platform using a third party service, or link your account to your account with a third party service, we may receive information about you from such third party service. If you post content to a third party service through the Platform, that third party service will also receive that content, which will be visible to anyone that has access to it through that third party service. Some of our web pages utilize framing techniques to serve content to you from our third party partners. In such cases, please note that the information you provide may be transmitted directly to the identified third party partner. If you interact with businesses through the Platform, they will receive whatever information you choose to share with them, for example contact information you share through direct messages to the business or your phone number if you call the business.

4. DATA RETENTION AND ACCOUNT TERMINATION

You can close your account through your account settings. We may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Platform or to comply with legal obligations. We may also maintain residual copies of your Personal Information in our backup systems. Please note that businesses cannot remove their business pages, ratings, or reviews by closing their accounts.

5. MINORS

The Platform is intended for adult audiences and is not directed to users under 18. We do not knowingly collect Personal Information from users under 18. If you become aware that a child has provided us with personal information without parental consent, please contact us at the address listed below in the “Contact” section. If we become aware that a user under 18 has provided us with Personal Information without parental consent, we take steps to remove such information and terminate the user’s account.

6. SECURITY

We endeavor to use reasonable organizational, technical, and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at the address listed below in the “Contact” section.

7. CONTACT

You may contact us online concerning our Privacy Policy, or write to us at the following address: lombardy [at] richobo.com

For security purposes, we will take such steps as we deem necessary to confirm your identity before completing your request or sharing any personal data with you.

8. MODIFICATIONS

We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you. If we make material changes to this Privacy Policy which require notification to users, we will notify you by email or by posting a notice on the Platform prior to or on the effective date of the changes. By continuing to access or use the Platform after those changes become effective, you acknowledge the revised Privacy Policy.

9. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding our collection, use, and sharing of their personal information.

We do not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.

We collect various categories of personal information when you use the Platform, including Cookies, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information.

If you are a resident of California, you have the right to request to know what Personal Information has been collected about you, and to access that information. You also have the right to request deletion of your Personal Information, though exceptions under the CCPA may allow us to retain and use certain Personal Information notwithstanding your deletion request. You can learn more about how to submit a data rights request by contacting us at the address listed above in the “Contact” section. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what Personal Information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above.

10. NEVADA RESIDENTS: YOUR NEVADA PRIVACY RIGHTS

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your Personal Information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at the address listed in Sec. 7 above.

11. EUROPEAN RESIDENTS: YOUR PRIVACY RIGHTS AND INTERNATIONAL DATA TRANSFER

If you are a European Resident, you have the right to access your personal data, and the right to request that we correct, update, or delete your personal data. You can object to the processing of your Personal Information, ask us to restrict processing of your Personal Information, and request portability of your Personal Information. Additional information regarding your exercise of these rights is available upon request. Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal information conducted in reliance on lawful processing grounds other than consent. The Platform generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you or in your account settings. If you have any questions or comments about the processing of your personal information, you may contact us as described in Section 7 above.

For European Residents, please note that the Personal Information we obtain from or about you may be transferred, processed, and stored outside of the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States of America. We strive to comply with the European Union General Data Protection Regulation ("GDPR"). Please review our "GDPR Statement" posted on the Platform.

All materials © 2024 Almanach Group LTD, unless otherwise noted. All rights reserved.