Privacy Policy

PRIVACY POLICY

Last Updated: June 21, 2023

  1. INTRODUCTION

AGREEMENT AND PARTIES. Ryan Hughes (“Company,” “us,” or “we”) respects the privacy of the visitors to the Ryan Hughes website (“website” or “site”). This Privacy Policy (“Privacy Policy” or “Policy”) is an agreement between Ryan Hughes and you, as the user of the Ryan Hughes website (“you”). This agreement tells you when this Policy is effective, what information we collect from you, how we might use it, how you can review or change the personal information you provided to us, how we may change this Policy, and the steps we take to ensure that your personal information is protected.

  1. AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE

AGREEMENT TO TERMS. All activities in which you may engage on this website are voluntary. You are not required to provide any personal information to us unless you choose to access features on this site that require the information. If you do not agree with the terms of this Policy or other terms of use on this website, then you should immediately exit this website and discontinue using the site. If you do not agree with the terms of this Privacy Policy, please do not provide us with personal information, and leave this website. By using the Ryan Hughes website, you signify that you agree to the terms of this Privacy Policy as well as to our terms of use.

  1. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY

EFFECTIVE DATES. This Privacy Policy is effective as of June 21, 2023, and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the website or we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this Policy periodically, as its terms may change from time to time. Your continued use of the site after we post any such modifications will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “last updated” date found at the beginning of this Privacy Policy when we post changes to it.

  1. POLICY APPLICABLE TO ONLINE ACTIVITIES ONLY

4.1 DISCLAIMERS. This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Ryan Hughes’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. This online Privacy Policy only applies to information collected through this site and the ALPR system described in Section 13. This Privacy Policy does not apply to any other information we may collect from you.

4.2 CALIFORNIA CONSUMER PRIVACY ACT (CCPA) INAPPLICABLE. Since Ryan Hughes is not a “business”, as defiled by the CCPA, the CCPA is generally inapplicable to Ryan Hughes. Accordingly, nothing in this Privacy Policy will be construed as subjecting Organization to the requirements and/or liabilities of the CCPA. Unless and until the CCPA becomes applicable to Ryan Hughes, any provisions of this Privacy Policy describing rights available under the CCPA are inapplicable. The terms of this paragraph controls over any conflicting terms of another.

  1. PERSONAL INFORMATION WE MAY COLLECT

TYPES OF INFORMATION COLLECTED. We may ask you for certain information referred to on this site as “personal information,” which includes information that pertains to your identity. Such information may include, but is not limited to, items such as your name, address, date of birth, age, gender, email address, telephone number, car make, car model, or license plate number. You may be required to provide personal information to access or use certain parts of our website or features of the site. If you do not provide the requested personal information, you may not be able to access or use the features of the site where such information is requested.

  1. GENERAL INFORMATION WE MAY COLLECT

TYPES OF INFORMATION COLLECTED. There may be other instances in which we collect information from you that is more general in nature (“general information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the internet. Such general information, including the click stream data and cookies, as mentioned below, may be collected from you whenever you access the site, whether or not you provide us with any other personal information.

A set of website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you access this website through a mobile device, then we may collect information about your mobile device whether or not you provide us with any other personal information.

6.1. Your rights under the CCPA:

You have the right to know what categories and/or specific pieces of personal information are collected about you. As such, you may submit a verifiable consumer request via the following methods: sending an email to privacy@breakthroughdevgroup.com or sending a letter to Ryan Hughes, 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362.

You have the right to know what personal information is sold or disclosed to third parties. You may submit a verifiable consumer request via the following methods: sending an email to privacy@breakthroughdevgroup.com or sending a letter to Ryan Hughes, 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362.

Ryan Hughes does sell personal information as defined by the CCPA.

Subject to statutory exemptions and exceptions, you have the right to request that we delete the personal information that we have collected about you. You may submit a request for deletion via the following methods: sending an email to privacy@breakthroughdevgroup.com or sending a letter to Ryan Hughes, 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362.

If you exercise your rights under the CCPA, you have the right to not be discriminated against.

6.2. Click Stream Data
When you visit our website, we may also collect “click stream data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis or e-commerce analysis of our website, to determine which features of our site are most or least effective or useful to you.

6.3. Cookies
We may also use cookies to gather information about your visits to our website and enhance your experience. More information on how we use cookies is available in Section 11.

6.4. How We Respond to “Do Not Track” Disclosures
We are strongly committed to not sharing personal information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Policy. Because we protect all users in this manner, we do not change our behavior in response to a web browser’s “do not track” signal.

6.5. Use of Social Media Tools
This website may allow you to use your social media accounts to pre-populate certain fields. If you choose to use this feature, you are allowing us to access your personal information. We encourage you to review the privacy policy and any terms and conditions for the social media platform you select.

  1. INFORMATION ABOUT YOU

USE OF INFORMATION. We will primarily use the personal information you provide and any general information we receive from you to provide products and services to you, including, but not limited to, the following:

A. To send you information or materials via email about products, offers, and news we think might interest you. This information may relate to products, offers, and news of Ryan Hughes or its licensees or selected commercial partners. We send you this only if you have double-opted-in to receive emails from Ryan Hughes. If you no longer wish to receive any emails from us, or if you want to modify your personal data or want your personal data to be deleted from our database, see Section 12.

B. To analyze visits to the website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features, and promotions that you are most interested in.

C. In the case of ALPR data (more fully described in Section 13, below), to safeguard Ryan Hughes’s home from criminal activity.

  1. PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION

8.1. Security Measures
In order to protect both the personal information and the general information that we receive from you through our website, we have implemented various security measures, including utilizing two-factor authentication (2FA) where available, utilizing encrypted hard drives and data transmission where available, and reasonably restricting access to systems.

8.2. Risk of Interception
Please keep in mind, however, that whenever you give out personal information online, there is a risk that third parties may intercept and use that information. While Ryan Hughes strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using this site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this site and that any personal information, general information, or other data or information received from you through the site is provided to us at your own risk, which you expressly assume.

  1. NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED

9.1 Registration Declined
Ryan Hughes intends only persons who are 18 years or older to use this website. Personal registration information submitted by a person under the age of 18 will not be accepted. Any general information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during their visit may be used as indicated in this policy (see Section 6). Ryan Hughes is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of email and other activities online.

9.2. Notice Concerning Children
PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a site user is under age 13, we will promptly delete any personal information in that user’s account.

  1. THIRD PARTIES

10.1. Sharing Information With Persons or Entities Who Manage This Website
Ryan Hughes’s global and local websites and the personal information and general information collected are managed and controlled by Ryan Hughes located at 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362. The servers that make Ryan Hughes’s global and local websites available are located in the United States. If you are located outside the United States, please note that the information you provide will be transferred to Ryan Hughes, and by submitting the information you authorize this transfer. Ryan Hughes has entered into an agreement with the hosting company in the United States to provide safeguards for the protection of your data that are consistent with this policy.

10.2. Disclosing Information to Third Parties

WHO MAY HAVE ACCESS TO YOUR INFORMATION. Other than to the companies belonging to Ryan Hughes for the purposes set out above, and except as described in this Policy, we do not sell, trade, or otherwise transfer your personal information or general information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “service partners”). Our service partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the website, executing services (such as for prize fulfillment), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control. Please also see Paragraph 6.4 on how we will respond to “do not track” signals.

10.2.1. Categories of Personal Information Collected
We currently collect name, email address, license plate numbers, car makes, and car models.

10.2.2. Categories of Third Parties to Whom Personal Information Is Disclosed and the Corresponding Categories of Personal Information Disclosed
We disclose name and email address to software vendors who help us send newsletters and email communications. We also contract with Rekor, a company with software to analyze and process license plate, car make, and car model data.

10.2.3. Categories of Third Parties to Whom Personal Information Is Sold and the Corresponding Categories of Personal Information Sold
We do not sell consumer data.

10.3. Security
RELEASE OF INFORMATION. Ryan Hughes will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose personal or general information on receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this agreement, to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.

10.4. Links to Third Parties
PURPOSE OF LINKS. For your convenience and to improve usage of the website, we may insert links to third parties on this site. This Privacy Policy does not apply to such third party websites. These links take you outside our service and off the Ryan Hughes’s site and are beyond our control. This includes links from partners that may use Ryan Hughes’s logos as part of a co-branding agreement. The sites those links can take you to have their own separate privacy policies and, although we seek to protect the integrity of our site, Ryan Hughes is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.

  1. AUTOMATIC COLLECTION
    COOKIES. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used for such activities as remembering your username and password, if you use such a feature on this site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options, you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit and you may lose access to some of its features.
  2. DELETING OR MODIFYING PERSONAL INFORMATION
    CHANGING YOUR INFORMATION. You may cancel your registration at any time, and you may opt out of receiving any emails from Ryan Hughes.

12.1. Right to Opt Out of the Sale of Personal Information
We do not sell information as defined under the CCPA.

12.2. Right to Request Deletion of Personal Information
Subject to statutory exclusions, you have the right to request that we delete the personal information that we have collected about you. You may submit a request for deletion via the following methods: sending an email to privacy@breakthroughdevgroup.com or sending a letter to Ryan Hughes, 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362.

12.3. Update Your Contact Information
We encourage you promptly to update your contact and personal information when it changes.

  1. AUTOMATIC LICENSE PLATE READER DISCLOSURES

To comply with California Civil Code, Title 1.81.23, please note the following. This website operator operates an automatic license plate reader (ALPR) system for the sole authorized purpose of safeguarding Ryan Hughes’s home from criminal activity. Ryan Hughes contracts with Rekor, a company with software to analyze and process license plate data. There are no other employees or contractors who utilize the ALPR system, and there are no training requirements. The ALPR system will always be password-protected to ensure compliance with applicable privacy laws. Data generated by the ALPR system will only be shared with Rekor for purposes of processing ALPR data. Rekor may use ALPR data for: a) facilitating sharing of ALPR data with other governmental or quasi-governmental agencies and b) training and performance enhancement of Rekor’s AI system. It may also use de-identified ALPR data for: a) statistical, volume, and flow analysis, and b) sharing with other governmental or quasi-governmental agencies, or commercial entities. Please refer to the Privacy Policy and License Agreement on Rekor’s website for more information. Ryan Hughes does not sell ALPR data. Ryan Hughes is the owner of the ALPR system responsible for implementing California Civil Code, Title 1.81.23. Ryan Hughes only anticipates using the ALPR system to monitor a small number of individuals. All other ALPR data will be disregarded or deleted to the greatest extent possible. Information retained will always be compared to source data, i.e., images and video, to ensure accuracy. Any relevant ALPR data generated for the purposes described in this paragraph will be retained as long as legally necessary to ensure Ryan Hughes’s safety. All other data will be disregarded and destroyed as soon as practically possible.

  1. QUESTIONS OR COMMENTS
    CONTACT INFORMATION. If you have any questions or comments relating to our website or this Privacy Policy, send an email to privacy@breakthroughdevgroup.com or send a letter to Ryan Hughes, 3717 E. Thousand Oaks Blvd., Westlake Village, CA 91362.