We respect your privacy and the importance of the information you entrust to us. This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
By accessing or using the Service, you are accepting the policies and practices described in this Privacy Policy. Each time you visit or use the Service, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Service.
Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through the Service. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application means the software program provided by the Company downloaded by You on any electronic device, named Redactable
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Redactable Inc., 447 Broadway, 2nd FL New York, New York 10013.
• Consumer, refers to a resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose. For the purpose of the CCPA (California Consumer Privacy Act), Consumer means a natural person who is a California resident.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. This Privacy Policy applies in circumstances where We are acting as a Data Controller with respect to the Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
We collect information you provide directly to us when using the Service. For example, we collect information when you download our Application, register for our Service, sign up for an account, complete a form, participate in any interactive features of the Service, request customer support, or otherwise communicate with us. The types of information we may collect include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Any other information you choose to provide
We will never sell, rent, trade or use Personal Data other than as needed to provide the Service requested by you. If you choose not to provide information that is necessary to provide the Service, you may not be able to use certain aspects or all of the Service. Company discloses Personal Data only to those of its employees, contractors and Affiliates that (i) need to know the information in order to process it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least as strong as those herein.
You acknowledge and agree that communications, including phone calls or “chat” services, with Company or our third-party agents may be monitored, recorded and retained by Company. You consent to the monitoring and recording of all conversations between you and Company and you release us from and against any and all claims, liabilities and losses that may result from any such monitored and/or recorded conversations.
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may associate your device identifiers or phone number with your account. Depending on the nature of your inquiry or activities on the Service, we may also ask for other information relevant to your use of the Service.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
• To provide, maintain and improve our Service, including to monitor the usage of our Service.
• To manage Your Account and Your preferences: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the services You have purchased or of any other contract with Us through the Service.
• To process payment and facilitate use of the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• For Customer Support: To prevent or address service, security, technical issues at your request in connection with customer support matters
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us. And to respond to your comments, questions, and requests;
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• To enforce our Terms of Service.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
• To carry out any other purpose for which the information was collected.
This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user of the Service. In other words, information about how You use the Service may be collected and combined with information about how others use the Service, but no personally identifiable information will be included in the resulting data.
We may share Your personal information in the following situations:
• With Service Providers: We may share Your personal information with Service Providers in connecting with providing the Service, to monitor and analyze the use of our Service, for payment processing, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our Affiliates and contractors who need access to such information to carry out work on Our behalf, in which case we will require those Affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent or at your discretion, including if we notify you through the Service that certain information you provide will be shared in a particular manner and you provide this information .
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary to fulfill the original purposes for which it was collected and as set out in this Privacy Policy. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
The criteria used to determine Our retention periods include:
• Time needed to provide you with Our Service.
• Whether your account with us is active. You may contact us to make your account inactive at any time.
• Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.
Please note that We are not responsible for storing any information that You provide to Us or for any content or information that We provide to You. You are solely responsible for retaining backup files of any information and content that You provide or receive in connection with the Service.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices in the United States and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. If you are located outside of the United States, any information you provide to us may be transferred out of your country and into the United States. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. Personal Data collected through the Service may be stored and processed in the United States or, if and as applicable for international Users, any other country in which Company or its Affiliates, subsidiaries or service providers maintain facilities. If your Personal Data is transferred to a country other than your home country, we will take measures to protect it with appropriate contract clauses or other applicable safeguards.
Your submission of such information represents Your agreement to that transfer.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
Security of Your Personal Data
We work hard to protect your information and take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard personal information from loss, unauthorized access, alteration, or disclosure regardless of how or where it is stored. The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the user experience, and better understand your activity.
• Google Analytics
• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
• Mixpanel
• Mixpanel is provided by Mixpanel Inc.
• You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
• For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
• Hubspot
• Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy
Payments
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
• Stripe
• Their Privacy Policy can be viewed at https://stripe.com/us/privacy
Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Service.
• FreshDesk
• FreshDesk is a customer support software. The service is operated by Freshworks, Inc.
• FreshDesk service may collect information from Your Device.
• The information gathered by FreshDesk is held in accordance with its Privacy Policy: https://www.freshworks.com/privacy/
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please 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 Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
CCPA Privacy
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
• Category A: Identifiers.
o Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
o Collected: Yes.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
o Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
o Collected: Yes.
• Category C: Protected classification characteristics under California or federal law.
o Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
o Collected: No.
• Category D: Commercial information.
o Examples: Records and history of products or services purchased or considered.
o Collected: Yes.
• Category E: Biometric information.
o Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
o Collected: No.
• Category F: Internet or other similar network activity.
o Examples: Interaction with our Service or advertisement.
o Collected: Yes.
• Category G: Geolocation data.
o Examples: Approximate physical location.
o Collected: No.
• Category H: Sensory data.
o Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
o Collected: No.
• Category I: Professional or employment-related information.
o Examples: Current or past job history or performance evaluations.
o Collected: No.
• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
o Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
o Collected: No.
• Category K: Inferences drawn from other personal information.
o Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
o Collected: No.
Under CCPA, personal information does not include:
• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above categories with the following categories of third parties:
• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
o The categories of personal information We collected about You
o The categories of sources for the personal information We collected about You
o Our business or commercial purpose for collecting or selling that personal information
o The categories of third parties with whom We share that personal information
o The specific pieces of personal information We collected about You
o If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
o The categories of personal information categories sold
o The categories of personal information categories disclosed
• The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
o Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
o Debug products to identify and repair errors that impair existing intended functionality.
o Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
o Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
o Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
o Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
o Comply with a legal obligation.
o Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
o Denying goods or services to You
o Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
o Providing a different level or quality of goods or services to You
o Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
• By email: support@redactable.com
• By visiting this page on our website: https://support.redactable.com
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We cannot:
• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
We do not sell your personal information. In the event that changes, You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.
Promotional Communications
By providing Personal Data to Us, You expressly consent to receive messaging and information from Us. You may opt out of receiving promotional communications from Us by following the instructions in those communications or by emailing Us at support@redactable.com. If You opt out, We may still send You non-promotional communications, such as messages about Your account or our ongoing business relations.
If You have consented to have your Personal Data shared with any third party and You no longer wish to have Your Personal Data shared with such parties, then you may opt-out of such disclosures by sending an email to support@redactable.com. However, We are not responsible for removing Your Personal Data from the lists of any third party who has previously been provided with Your information in accordance with this privacy policy or Your separate consent.
Please note that there might be a brief delay between when You submit Your request to 'opt-out' and when it is processed and reflected in Our systems; accordingly, You may continue to receive communications from Us for a limited time after You unsubscribe. We appreciate your patience.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If You'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Your continued use of the Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended.
Non-Discrimination
We will not discriminate against You because You elect to exercise any of the rights related to your Personal Data, including but not limited to:
• Denying you products or services;
• Charging you different prices or rates for the Service, including through the use of discounts or other benefits or imposing penalties on You;
• Providing a different level or quality of the Service to you; or
• Suggesting that you will receive a different price or rate for the Service or a different level or quality of the Service.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
• By email: support@redactable.com
• By visiting this page on our website: https://support.redactable.com
STATE ADDENDUM
Notice of Colorado, Connecticut, Montana, Oregon, Texas, Virginia and Utah Privacy Rights
The section relates solely to residents of the States of Colorado, Connecticut, Virginia and Utah, and provides you with information about your privacy rights under the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CDPA), the Montana Consumer Data Privacy Act (MCDPA), the Oregon Consumer Privacy Act (OCPA), the Texas Data Privacy and Security Act (TDPSA), the Virginia Consumer Data Protection Act (VCDPA) and the Utah Consumer Privacy Act (UCPA).
This section shall be effective for the residents of those States on the dates set forth below:
• Effective January 1, 2023, for residents of the State of Virginia
• Effective July 1, 2023, for residents of the States of Colorado and Connecticut
• Effective December 31, 2023, for residents of the State of Utah
• Effective July 1, 2024 for residents of the State of Oregon
• Effective July 1, 2024 for residents of the State of Texas
• Effective October 1, 2024 for residents of the State of Montana
For purposes of this section, "residents", "consumers" or "you" means individuals of those states who are acting in their individual or household context. This section does not apply to individuals acting in their commercial or employment context.
1) Personal Information we collect
You have a right to know the categories and types of personal information we collect about you. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
2) Categories of sources from which we collect personal information
You have the right to know the categories of sources from which we collect your personal information. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
3) Our processing of your personal information
You have the right to know how we process and use your personal information. We make this information available to you in the USE OF INFORMATION section of our Privacy Policy.
*For residents of the State of Virginia, to the extent that we maintain de-identified data, we take reasonable measures to ensure that de-identified data cannot be associated with a natural person, we publicly commit to maintaining and using de-identified data without attempting to re-identify the data, and we contractually obligate any recipient of the data to comply with the same obligations.
4) Disclosure of Personal Information
You have the right to know if we share your personal information with any third parties. We make this information available to you in the SHARING OF INFORMATION section of our Privacy Policy.
5) No Sale of Data or Use of Data for Targeted Advertising
We do not sell your personal information and we do not use your data for targeted advertising (as that term is defined by your applicable state law). We may send you advertising in response to your request for information or feedback or based on your activities with our Services, including your search queries and visits to our Services. However, we will not send you targeted advertising based on your activities across non-affiliated websites, applications or platforms to predict your preferences or interests.
6) Your Rights
a) Where we act as the Controller of your personal information (as opposed to a Processor as those terms are defined in your applicable State law), you have the right to submit a request to us for the following:
• Right to access. You have the right to know if we process your personal information and have access to such information and certain details of how we use it.
• Right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.
• Right to delete. You may have the right to request that we delete your personal information where we act as a controller. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our processors to:
o Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;
o Detect bugs or errors in our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
o Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
o Comply with a legal obligation; or
o Make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.
• Right to restriction of processing (opt-out). You have the right to opt-out of processing your personal information for purposes of profiling in furtherance of any automated processing of your data that produce legal or similarly significant effects concerning you. (This right only applies to residents of the States of Colorado, Connecticut and Virginia.)
• Right to data portability. You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.
• Right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights, including but not limited to, by denying you goods or services, charging you different prices for goods or services, or providing you a different level or quality of goods or services.
• Right to restrict the processing of sensitive information
Unless we are processing your sensitive information pursuant to any of the legal exemptions listed in Section 8 (Exemptions) below or as otherwise allowed by law:
• For residents of the States of Connecticut, Virginia and Colorado, we will not process your sensitive information without first obtaining your consent; and
• For residents of the State of Utah, we will not process your sensitive personal information without providing you with notice and an opportunity to opt out.
b) Exercising Your Rights
You may exercise your rights to know, delete and correct as described above by submitting a verifiable request to us by emailing us at support@redactable.com.
c) Authentication Process
We will only fulfill request when we can verify your identify and confirm that you are authority to make such a request. Only you, you as the parent or legal guardian on behalf of your minor child, or your authorized agent, guardian or conservator may make a request related to personal information. If an authorized agent, legal guardian or conservator submits the request, we may require your written permission to do so and may require additional information to authenticate your identity. We may deny a request by an authorized agent, legal guardian or conservator who does not submit proof of authorization to act on your behalf. We will only use the personal information you provide in a request to verify your identity or authority to make the request.
d) Response Timing and Format
We will respond to an authenticated request within forty- five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If we cannot comply with a request or a portion of the request, we will include the reasons in our response.
*For residents of the States of Colorado, Connecticut and Utah, you may make one request within a twelve-month period at no charge.
*For residents of the State of Virginia, you may make a request up to two (2) times within a twelve (12) month period at no charge. We reserve the right to charge a fee to process or respond to any request that we consider excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7) Right to Appeal
You have the right to appeal our decision within a reasonable period of time after receipt of our response. You may appeal our decision by sending us an email at support@redactable.com. We will respond to your appeal within 60 days of receipt (45 days of receipt for residents of Colorado) and will inform you of any decisions and the reasons for such decisions.
* Please note that in certain cases we may collect your personal information as a processor (as opposed to a controller, as those terms are defined in your applicable state privacy law) pursuant to a contract we have with a commercial client (the controller) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the controller. Should you direct your requests to exercise your rights to us, we may be required to share your request with the controller, who is the party responsible under your applicable state privacy law for receiving, authenticating and responding to your requests.
8) Exemptions
This section (Notice of Colorado, Connecticut, Montana, Oregon, Texas, Virginia and Utah Privacy Rights) does not apply to certain entities and data that are exempt from your applicable state privacy law, including but not limited to the following: covered entities, business associates and protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH); financial institutions and personal information subject to the Gramm-Leach-Bliley Act (GLBA); and personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Family Educational Rights and Privacy Act, the Farm Credit Act and the Driver's Privacy Protection Act of 1994 (DPPA).
CANADA ADDENDUM
ADDENDUM DATE: June 13, 2024
This Canada Addendum to the Company Privacy Policy (“Canada Addendum”) supplements the terms of Company’s Privacy Policy and applies to individuals who are residents of Canada, as specified below. It describes the rights you may have, depending on the state of your residence, with regard to your personal information, which apply when new or updated laws take effect in these states. This Addendum does not apply to any employees, owners, directors, officers, or contractors of Company or its affiliates.
CANADA
Your Canada Rights Regarding Your Personal Information. Federal and provincial Canadian laws provide individuals with some or all of the rights listed below. To exercise these rights see the “Exercising Your Canada Privacy Rights” section below.
Right to Know. You have the right to know we have processed your personal information and to request access to the personal information we have collected about you.
Right to Correct. You have the right to request that we correct inaccurate personal information.
Right to Delete. In some circumstances, you have the right to request that we delete the personal information we have collected about you.
Right to Opt Out. Depending on the location from which you are using our services, you have the right to opt in or out of targeted advertising (as defined under applicable law) and the use of cookies and similar technologies for non-essential purposes like targeted advertising.
Withdraw Consent. You have the right to withdraw your consent to our collection, use or disclosure of your personal information at any time, subject to contractual and legal restrictions and reasonable notice.
Exercising Your Canada Privacy Rights. Company has designated a Data Privacy Officer (DPO) who is accountable for ensuring Company’s compliance with its Privacy Policy and applicable laws. The Company DPO may delegate their obligations to others from time to time. To contact the Company DPO, request access to or deletion of your personal information, or to exercise any other privacy rights under Canada law, please contact us by email at support@redactable.com.
Authorized agents can make a request on your behalf if you have given them legal power of attorney or we are provided proof of signed permission, verification of your identity, and, in some cases, confirmation that you provided the agent permission to submit the request.
Transfer of Data: In providing you with the Company services, Company or its service providers may process, store or communicate your personal data outside of your province of residence or outside of Canada.
Children: Company is not directed to children, and we don’t knowingly collect personal information from children under the age of 16. If we find out that a child under 16 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 16 has given us personal information, please email at support@redactable.com.
