Runway’s California Privacy Policy

Last revised: August 23, 2021

This California Privacy Policy applies solely to individual residents of the State of California (“consumers” or “you”) and is supplemental to the information contained in our Privacy Policy.

Capitalized terms not defined in this CPP shall have the same meaning as defined in our Privacy Policy or as otherwise defined in the California Consumer Privacy Act of 2018 (“CCPA”).

This CPP provides consumers with additional information on how Runway collects, uses, discloses, and otherwise processes Personal Information of individual consumers who reside in the State of California, either online or offline, within the scope of the CCPA.

How We Collect Personal Information

For purposes of this CCP, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include:

• Information relating to our job applicants, contractors or personnel;
• Certain information about our interactions with our business-to-business (“B2B”) contacts;
• Publicly available information from government records;
• Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to an individual consumer or household;
• Information excluded from the CCPA’s scope. Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of Personal Information from the categories of sources and for the purposes listed below.

The Personal Information that we collect may be used for any of the following purposes:

• Updating your payment information
• Developing marketing and customer relationship management activities
• Operate, evaluate, secure, and improve our business
• Providing you with and managing access to our products and services
• Collecting feedback
• For financial and engagement analytics
• Subscription forecasting purposes
• Personalization purposes
• Enhancing online security
• Preventing, investigate, and respond to fraud or other illegal activity
• Complying with legal process and our legal obligations
• Supporting investor relations
• As otherwise provided in our agreements with you

How We May Disclose Personal Information 

In the last 12 months, we have not made Personal Information available to third parties for monetary or other valuable consideration. We do not “sell” Personal Information as such term is generally understood. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see “To Exercise Your Right to Opt-Out of Personal Information Sales” section below.

Personal Information may have been made available to the services identified in our Privacy Policy in this disclosure as part of the limited integration with such services on our website. Such Personal Information includes the following categories of Personal Information which reference the categories of Personal Information described above:

• Identifiers, such as name, address, and email address
• California Customer Records, Civ. Code § 1798.80(e)
• Commercial Information, such as investment information
• Internet/Network Information, such as device information, log, and analytics data
• Inferences, including information generated from your use of our websites reflecting your preferences

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law and the Personal Information definition exclusions noted above).

• The Right to Know

• Specific pieces of Personal Information we have collected about you,
• Categories of Personal Information we have collected about you,
• Categories of sources of the Personal Information we have collected about you,
• Categories of Personal Information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed,
• Categories of Personal Information we have sold about you (if any), and the categories of third parties to whom this information was sold, and
• Business or commercial purposes for collecting or, if applicable, selling Personal Information about you.

• The Right to Request Deletion

• You have the right to request the deletion of Personal Information that we have collected from you, subject to certain exceptions.

• The Right to Opt-Out of Personal Information Sales

• You have the right to direct us not to sell Personal Information we have collected about you to third parties now or in the future, subject to certain exceptions. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sale.

• The Right to Non-Discrimination

• You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

How to Exercise Your California Privacy Rights

• To Exercise Your Right to Know or Right to Deletion: Please submit a request to support@runwayhealth.com with the subject line “California Rights Request” and include your contact information and the full details of your request.  We will need to verify your identity before processing any request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  Although we try to limit the Personal Information collected in connection with a request to exercise the right to know and/or the right to deletion to that Personal Information, certain requests may require us to obtain additional Personal Information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

• To Exercise Your Right to Opt-Out of Personal Information “Sales: You may initiate your request to opt-out by sending us an email at support@runwayhealth.com with the subject line “California Opt-Out”. We need your name and email address in order to process your request and safeguard your data. To the extent that our third-party advertising and analytics providers’ collection of information from users of our websites and other online services constitutes a “sale” under the CCPA, please refer to the ‘Advertising’ section of our Privacy Notice for more information about the choices and opt-out options you have in relation to those practices. By visiting www.privacyrights.info, you can also opt out from “sales” of this type of Personal Information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.

• Minors Under Age 16: We do not sell the Personal Information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt-In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Updates to this California Privacy Policy

We will update this California Privacy Policy from time to time.  If we make material changes to this California Privacy Policy, we will notify you at the email address you provided, by a prominent posting on our Site, or through other appropriate means of communication. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this California Privacy Policy or other privacy-related matters, please send an email to support@runwayhealth.com.