Please Read This Privacy Policy Carefully.

Privacy is very important to Rulex, Inc. (“Rulex” or “we” or “us” or “our”). We also understand that privacy is very important to you. This Privacy Policy tells you how we protect and use information that we gather through the Rulex website.

This policy describes the types of information Rulex may collect from you or that you may provide when you visit our website https://www.rulex.ai/ (the “Website”), when you fill out a form, or contact us through the Website. It also explains how we collect, use, maintain, protect, and, in some circumstances, disclose that information.

Certain information we collect is necessary to complete our contractual or legal obligations, others are required for us to operate the Website. In some instances, the information we collect may be done only with your consent.

Please read this policy carefully to understand Rulex’s policies and practices regarding your information and how we will treat it. If you do not agree with Rulex’s policies and practices, you may choose not to provide us with the requested information or to decline to use the Website. By accessing or using the Website, and/or by providing Rulex with your information, you agree to this Privacy Policy.

We may change this Privacy Policy from time to time. We encourage you to review this Privacy Policy each time you visit our Website.

By using our Website, you agree to the terms of the most recent version of this Privacy Policy. Please read our Terms of Use to understand the general rules about your use of our Website.

Rulex complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Rulex has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Rulex is under the jurisdiction as well as the investigatory and enforcement powers of the US Federal Trade Commission for purposes of the EU-US Privacy Shield Framework.

INTRODUCTION

The information we receive, and how we use it, depends on what you do when visiting our Website, how your browser is configured, and what information you provide to us. We collect and use your personal information differently than your non-personal information (information that is not identifiable to you personally).

WHAT IS PERSONAL INFORMATION?

Personal information is information we collect through our Website that we can use to specifically identify you, such as your:

  • Name
  • Telephone number
  • Address
  • E-mail address
  • Work information
  • Date of birth

We also collect your IP address when you use our Website, which in some circumstances can be considered personal information.  Other than the IP address, we do not automatically collect personal information, though in some places on our Website you have the opportunity to send us such information about yourself. For example, you may fill out a registration form, a survey, or a contact form.

HOW DO YOU COLLECT INFORMATION ABOUT ME?

Information You Give Us:

Rulex receives and stores information you enter on the Website or give us in any other way.

Examples of the information you may give Rulex includes:

  • Information that you provide by filling in forms on the Website, including your name, title, work information, e-mail address, mailing and billing addresses, telephone numbers, usernames/screen names and passwords, and zip codes
  • Information you provide when you contact us through the Website or by e-mail
  • Information you provide us through use of our products and/or services
  • Information you give us when downloading a demo version of our software
  • Records and copies of your correspondence (including postal and e-mail addresses), if you contact Rulex
  • Your responses to surveys that we might ask you to complete
  • Information you provide through registrations on the Website
  • Your search queries on the Website

We use the information that you provide for such purposes as responding to your requests, keeping you informed of news and information about Rulex, customizing future visits to our site, improving our Website or products, and communicating with you.

If you do not want us to have this information, you can choose not to provide it to us, but then you might not be able to take advantage of many of Rulex’s services or features.  See “What Choices Do I Have?”

Automatic Information We Collect:

The Website collects a set of general data and information each time you visit. The information includes:

  • Your browser type and the version used
  • Your operating system
  • The website from which you accessed our Website (so-called referrers)
  • The links within the Website that you visit while accessing our Website
  • What pages you access or visit
  • The date and time you accessed the Website
  • Your Internet Protocol (IP) address and domain name
  • Your Internet service provider
  • Other similar data and information required for security purposes in the case of

attacks on our information technology systems

We do not attempt to draw any conclusions about you from this general information. Instead, we use this information to:

  • Deliver the contents of our Website correctly
  • Optimize the content of our Website and the advertising for it
  • Improve the long-term functionality of our information technology systems and the technology of our Website
  • Recognize you when you return to the Website
  • Monitor and respond in case of a cyber attack
  • Provide information to law enforcement authorities in the event of a cyber attack

In general, we use this information to improve the security and performance of our Website as well as to evaluate and improve the products and services we offer, whether on our Website or otherwise.

For more information about these automated collection techniques, see “Does Our Website Use Cookies?”

HOW DOES RULEX KEEP AND USE PERSONAL INFORMATION?

We may keep and use personal information we collect from you through our Website to provide you with access to the Website. In addition, Rulex may keep and use your personal information to:

  • Respond to your requests
  • Distribute requested reference materials
  • Provide information about products and services
  • Arrange for software demonstrations, reviews and analyses, and free trials
  • Deliver the contents of our Website correctly
  • Optimize the content of our Website and the advertising for it
  • Personalize your access to our Website, for example, by telling you about new features that may be of interest to you
  • Improve the long-term functionality of our information technology systems and the technology of our Website
  • Recognize you when you return to the Website
  • Register you for certain areas of the Website, workshops, and other events
  • Inquire for more information
  • Develop records, including records of your personal information
  • Statistical use
  • Contact you with information that might be of interest to you, including information about products and services of ours and of others
  • Analyze research, develop and improve programs, products, services and content
  • Enforce this Privacy Policy and other rules about your use of our Website
  • Protect our rights or property
  • Protect someone’s health, safety or welfare
  • Comply with a law or regulation, court order or other legal process
  • Monitor and respond in case of a cyber attack
  • Provide information to law enforcement authorities in the event of a cyber attack

In some instances, we de-identify or aggregate data by removing personal information (such as your name, e-mail address, social security number, etc.). Once de-identified or aggregated, the data is no longer attributed to a single unique individual. De-identified or aggregated information is non-personal information that we may treat like other non-personal information.

DOES RULEX EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

Rulex values the information it has about its customers and is not in the business of selling it to others. We do occasionally need to share your information for the purpose of conducting our business with you or to comply with legal obligations.  For example, under certain circumstances, Rulex may need to:

  • Share personal information between Rulex and its sister company, Rulex Innovation Labs Srl, based in Italy
  • Disclose to trusted third parties, who are bound by contractual obligations to keep personal information confidential, to support our business, and to use it only for the purposes for which we disclose it to them
  • Comply with any court order, law, legal process, or to respond to any government or regulatory request, including requests related to laws outside of your country of residence
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us
  • Protect the rights, property, or safety of Rulex, its employees, customers, or others
  • Enforce our terms and conditions
  • Permit us to pursue available remedies and/or limit the damages that we sustain
  • Fulfill our recordkeeping obligations and practices
  • Fulfill any other purpose disclosed by us when you provide the information
  • Comply with your instructions or, if allowed to do so, with your consent

We may also need to provide the collected personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Rulex’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Rulex about its Website’s users is among the assets transferred.

Rulex may also transmit your information across borders as a function of its services and for purposes relating to the Website.We acknowledge our liability for such data transfers to third parties.

WHAT IS NON-PERSONAL INFORMATION?

If you visit our Website to read or download information, such as information about one of our products, we may collect certain non-personal information about you from your computer. This information is collected from your computer’s web browser. If you only read or download information on our Website, we do not collect or learn your name, e-mail address, home address, or other information directly identifying you.

“Non-Personal Information” is any information about you that does not reveal your specific identity, does not directly relate to an individual, and cannot be readily connected back to an individual such as:

  • Browser and device information
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other similar information provided by you
  • Usage Data including information about how you use our Website
  • Information from a referring website
  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences
  • Your zip code, postal code or area code when they are not connected to other personal information
  • Aggregated information
  • Personal information that has been de-identified

Sensitive Information

Sensitive information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. Rulex does not seek any sensitive information either through the website or from customers using its services. In fact, customers are asked to provide us with anonymized data, without personal information and without sensitive information.

WHAT DOES RULEX DO WITH NON-PERSONAL INFORMATION?

Because non-personal information cannot identify you or be tied to you, there are no restrictions on the ways that we can use or share non-personal information. For example, we will use non-personal information from you to help us make our Website more useful to visitors. We will also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate de-identified personal information to:

  • Create reports for internal use
  • Develop programs, products, services, or content
  • Customize the information or services that are of interest to you
  • Share it with or sell it to third parties
  • Provide aggregated “traffic statistics” and “response rates” to third parties

DOES OUR WEBSITE USE COOKIES?

Under some circumstances, we also collect information about your use of our Website by using what are known as browser cookies. Cookies are small text files that are saved to your computer automatically and that store certain settings and data to share with our system about your browser. Cookies help us to improve our Website and to be able to offer you a better service more tailored to you by recognizing your device and making pre-settings available to you.  In general, a cookie contains the name of the domain from which the cookie data was sent as well as information about the age of the cookies and an alphanumerical identifier.

In the cookies we use, only the data explained above about your use of the Website will be stored. There is no association with you personally.  Instead, an identification number is assigned to the cookie (“cookie ID”). The cookie ID will not be connected with your name, your IP address or with similar data that would allow the cookies to be connected with you.

If you do not wish to use browser cookies, you can set up your browser so that the storage of cookies is not accepted. Please note that in this case you may only be able to use our Website to a restricted extent or not at all.

MIGHT I ENCOUNTER ANY THIRD PARTY COOKIES?

Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Rulex does not control these third parties’ tracking technologies and may not control how they are used.

For example, Rulex utilizes Upland Software, Inc.’s Leadlander, to provide website visitor analytics, and Roxr Software Ltd.’s Clicky, to provide additional web analytics. For more information about Leadlander, please visit the Upland Software website at https://uplandsoftware.com/leadlander/.  You can review their Privacy Policy at https://uplandsoftware.com/privacy/. For more information on Clicky, please visit https://clicky.com/.  You can review their Privacy Policy at https://clicky.com/terms/privacy. To Opt-out of these cookies, please see What are My Choices?

If you have any questions about third party advertisements or other targeted content, you should contact the responsible provider directly.

WHAT ABOUT GOOGLE ANALYTICS?

The Website use Google Analytics, a web analytics service provided by Google, Inc. (“Google,” www.google.com), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses “cookies,” which are text files placed on your computer to help the Website analyze how users interact with the sites. The information generated by the cookies about your use of the Website will be transmitted to and stored by Google on servers in the United States.

Google normally anonymizes IP addresses, and only rarely transfers the whole IP address from outside the US to a Google server in the US.  In those cases, the IP addresses are shortened upon arrival on Google’s servers. Google uses this information on behalf of Rulex for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Website.

Google may also transfer this information to third parties if required to do so by law, or where third parties process the information on Google’s behalf.

For further information please visit: http://www.google.com/analytics/terms/gb.html.

By using Google Analytics, we aim to provide a faster and more stable service on our Website. Google Analytics allows us to optimize the loading times of our Website and better understand how users interact with them. Our legitimate interest in doing so is to allow us to improve our Website’s performance and to enhance our services for visitors to our Website.

By using our Website, you consent to Google processing data about you in the manner and for the purposes set out in this Privacy Policy. You may also choose to opt out of being tracked by Google Analytics in the future by installing an opt-out cookie. See “What Choices Do I Have?” for more information.

Data Processing Addendum:

We have concluded an appropriate data processing addendum with Google in order to fulfill privacy requirements under the GDPR.

If You Wish to Opt-Out of Google Analytics:

You can also opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your current web browser.

If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation will impact all affected tracking tags that are part of Google Analytics.

If you decide to opt-out, please be aware that the deactivation may mean that you cannot use all the features of our Website.

WHAT CHOICES DO I HAVE?

You can always choose not to input your information, even though it might be needed to take advantage of our services.

You can decline to accept cookies, set your browser to block cookies, or erase our cookies from your computer, though doing so may prevent some aspects of our Website from working properly.

You can prevent data collection by Google Analytics by clicking on the following link: https://tools.google.com/dlpage/gaoptout. This places an opt-out cookie, which prevents the future collection of your data when visiting our (or another) Website.  This opt-out cookie must be stored permanently on your computer. If you delete this opt-out cookie or it is deleted automatically via browser settings, you will have to install this opt-out cookie again when visiting our Website in the future.

For information about opting-out of the Clicky cookie, please visit https://clicky.com/optout.

In the event that you receive e-mail or other mail from Rulex and you wish to unsubscribe from  Rulex’s mailing list, please press the unsubscribe button on any of our e-mails or contact us at privacy@rulex.ai.

We store data for as long as it is necessary to provide the products and services described in this Privacy Statement, as required by law, and for our internal business purposes. If you would like for us to delete your data, you may contact us using the information below, and we will make reasonable efforts to accommodate your request.

If you want to exercise your rights over your data pursuant to GDPR (namely articles 15 and the following of the European Regulation 679/2016) or any similar law, please e-mail us at GDPR@rulex.ai. For details, see also “Can I Access, Correct or Delete My Data?” and “GDPR (European General Data Protection Regulation)” below.

WHAT ABOUT PRIVACY ON WEBSITES LINKED FROM RULEX.AI?

We may provide links to other companies on our Website. These external website addresses contain information that was published by organizations that are independent from us.  They are used to provide additional information as a service for visitors to our website.

We are not responsible for the content of the linked websites, other links that are found on such websites, or changes or updates to such websites. We do not review, control, or monitor the privacy practices of these websites, and this Privacy Policy does not apply to them. Such websites might use cookies to collect data or use this data in a way that we do not. We are not responsible for privacy policies or information or materials on these other websites.  Please read the privacy policies of these websites for information about their standards. The presence of these external links must not be seen as support for the content or opinions they contain.

DOES RULEX EVER COMMUNICATE DIRECTLY WITH VISITORS TO THE WEBSITE?

If you provide us with your contact information through one of our contact forms, we may contact you periodically by e-mail, mail or telephone to provide information consistent with the information you requested in completing our contact forms.

In addition, some of the features on the Website allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information, such as your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

We may also contact you in case it is required by regulators to inform you of crucial information about products updates.

ARE THERE SPECIAL RULES ABOUT CHILDREN’S PRIVACY?

Rulex cares about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us at privacy@rulex.ai.

WHAT ABOUT WEBSITE SECURITY?

We secure our Website and other systems through technical and organization measures against the loss, destruction, access, amendment, distribution, or unauthorized use of your data by unauthorized persons. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

CONTACT VIA THE WEBSITE

As required by law, our Website contains information that provides a means of e-mail contact to our company as well as other means of directly communicating with us. If you contact us by e-mail or other electronic means, the personal data you transmit is stored automatically. Such personal data will be stored for the purposes of responding to your inquiry, among other business purposes. If you use the contact form on our Website for your inquiry, you are giving your consent to the storage and usage of your personal data.  This personal data will not be passed on to third parties, unless otherwise indicated in this Privacy Policy.

HOW LONG DO YOU KEEP MY DATA?

In principle, we delete personal data when there is no requirement for further storage. A requirement may exist, in particular, if the data is still needed in order to be able to fulfill contractual obligations, to check warranty claims and, if applicable, guarantee claims and to grant or defend them. In the case of statutory retention obligations, deletion is only considered after the expiration of the respective retention period.

CAN I ACCESS, CORRECT OR DELETE MY DATA?

You may send us an e-mail at privacy@rulex.ai to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to access, change or delete information if we believe that doing so would violate any law or legal requirement, cause the information to be incorrect, or if we are not legally obligated to so. You may also access or correct your privacy preferences by sending us an email with your name, address, and email address (if different from the one you use to contact us) at privacy@rulex.ai.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of the Website that are California residents to request certain information regarding Rulex’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@rulex.ai.

GDPR (EUROPEAN GENERAL DATA PROTECTION REGULATION)I

If you are a European Union resident, or are otherwise a data subject covered by the European Union’s General Data Protection Regulation (GDPR) or similar laws in other countries, you may have certain rights in relation to your personal information.

Data Privacy Contact (representative) for European Union:

Rulex Innovation Labs Srl

Via Felice Romani 9/2

16122 Genova, Italy

Tel: +39 010 8050190

gdpr@rulex.ai

Legal Basis For the Processing of Personal Data:

We process your personal data only pursuant to the following legal basis:

  • Your prior consent
  • To fulfill contractual obligations
  • Legitimate interests of Rulex or Third Parties

In cases where we rely on legitimate interests for the processing of personal data those interest are described in this Policy under the relevant heading.

Data Processing Outside the European Union/European Economic Area:

All data gathered by Rulex, including European data is entered into a cloud-based platform run by a U.S.-based company.

European Union Data Subject Rights Pursuant to GDPR:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also may have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal information to you or to a third party (“Data Portability”). This enables you, or a third party you have chosen, to seek to have your personal information provided in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Complain to a data protection supervisory authority about the processing of personal data by us.

 

You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests in a timely manner. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.  We may also need to contact you about your request to verify your identity, confirm certain information, or clarify the request before we can fulfill the request.

If you are a European Union resident, or are otherwise a data subject covered by GDPR or a similar law, and would like to exercise these rights, or if you have questions about your rights please contact us at GDPR@rulex.ai or use the contact details of Rulex listed  below.

FEDERAL TRADE COMMISSION (FTC) ENFORCEMENT

Rulex is subject to the investigatory and enforcement powers of the Federal Trade Commision (FTC).

COMPLAINTS, INDEPENDENT RECOURSE MECHANISM, AND ACCESS TO FREE DISPUTE RESOLUTION

In compliance with the Privacy Shield Principles, Rulex commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Rulex at gdpr@rulex.ai or at the following addresses

437 Newtonville Ave.

Newton, MA 02460 USA

Phone: +1 617 244 1024

OR

Via Felice Romani 9/2

16122 Genoa, Italy

Phone:  +39 010 8050190

Fax:      +39 010 6475200

Rulex has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

USE OF ARTIFICIAL INTELLIGENCE

GDPR and other privacy regulations mandate special protections for profiling decisions in which automated processing of personal data is used to analyze or predict a person’s behavior. We do not use Artificial Intelligence (“AI”) to profile, as we do not collect personal or analyze personal data for this purpose.

Our AI solutions can be used by our customers to develop clear, interpretable rules that can be used to assist with decision making. The Rulex tool set always makes it possible to interpret and explain why a particular decision was made, and thus makes our customers’ compliance with GDPR and other regulations’ profiling mandates easier.

CHANGES TO OUR PRIVACY POLICY

It is Rulex’s policy to post any changes it makes to its Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website’s home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

HOW DO I CONTACT YOU?

If you have questions or comments about this Privacy Policy, please use the About Rulex – Contact link at the top of your screen or by contacting Rulex at:

437 Newtonville Ave.

Newton, MA 02460 USA

Phone: +1 617 244 1024

Email: privacy@rulex.ai

OR

Via Felice Romani 9/2

16122 Genoa, Italy

Phone:  +39 010 8050190

Fax:      +39 010 6475200

Email: GDPR@rulex.ai