Effective as of May 24, 2021.
- Our approach to information
- Information you provide us directly
- Information you provide us indirectly
- How we use this information
- How we share your information
- Storing and retaining your information
- Your choices regarding collection, use, and sharing of your information
- Rights in Certain Jurisdictions.
- Provisions Applicable to California, USA Residents.
- Provisions Applicable to Persons in the European Union and European Economic Area.
- Transfers of the information outside of the European Economic Area.
- Your rights.
- Contact Information.
1. Our approach to information
We collect your information directly only as required to communicate with you and fulfill your requests relating to our Sites, and indirectly only as indicated in our cookies policy referenced below. For example, if you request to be contacted regarding our events, we collect and store your relevant contact information. We only send emails to Users who explicitly opt-in or with whom we have established business relationships.
1.1 Information you provide us directly
In the course of establishing communication and maintaining our Sites, we receive “Personal Information” directly from Users. Personal Information means any information or data element that is associated with or may be used to identify an individual. Definitions of Personal Information vary by jurisdiction; however, here are some examples: contact information such as: first name, last name, phone (fixed/mobile) number, address, employer, title, social security number, mother’s maiden name, IP and/or MAC address, mobile device identifier, photographs, user-generated content, email address, user names, and transaction history; this is not an exhaustive list. Please note: we do not collect or store any credit card billing information; we delegate that sensitive task to a trusted service provider.
Our blog and community forums (“Social Sites”) are publicly facing which means the information you post, including any Personal Information, is public and immediately viewable, and searchable by Users of Social Sites. You do have the ability to use a pseudonym, if you prefer, to associate with your User persona to protect your identity. We only permit the administrator of our Sites, to access the User’s profile information for operational or troubleshooting purposes.
1.2 Information you provide us indirectly
Additionally, we may receive “Usage Data” indirectly from Users and link such data to Personal Information. Examples may include: browser type, operating system, webpage history, or internet service provider; this is not an exhaustive list.
2. How we use this information
Our practice is not to store, collect, or share Personal Information you share directly with us unless you opt-in explicitly. If you have not signed up to receive communications, registered with one of our Social Sites, nor requested us to perform any services for you, then you are not opted into any type of data collection or storage, with the exception of Usage Data, noted above, and cookies noted below. We use those sources of information not to perform a service, but to facilitate effective operation of our Sites and a positive User experience.
3. How we share your information
4. Storing and retaining your information
We store the aforementioned information on servers located in the United States of America. We keep Personal Information obtained through cookies for 30 days. Once that time period has expired, the information will be disposed of and any cookies will be reset. Other Personal Information obtained will be stored for the duration of our relationship and 120 days after the relationship has ended and/or consent (if applicable) is withdrawn.
5. Your choices regarding collection, use, and sharing of your information
As stated above, we believe in limiting the collection, use, and sharing of your Personal Information to the most reasonable extent possible, using it solely for the purpose that we disclose to you when we initially collect it. We also provide you with the ability to change your mind. For example, if you wish to opt-out of our newsletter mailings, you may select the opt-out link which can be found at the bottom of any message, in which case your email will be placed on a “do-not-mail” list and we will stop sending you any newsletters.
5.1 Rights in Certain Jurisdictions
Based on jurisdiction, there are may be certain access, erasure, and other rights which individuals may have to their data Personal Information, including the right to manage our treatment of their Personal Information and the way in which it is processes
5.2 Provisions Applicable to California, USA Residents
California Civil Code Section § 1798.80 et al provides certain rights pertaining to the use and disclosure of Personal Information. For example, § 1798.83 permits Users of our Websites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for direct marketing purposes. To make such a request, please send an email to [privacy at red9.com] or write us at: Red9.com, 11720 Amber Park Drive, STE 160, Alpharetta, GA 30009.
5.3 Provisions Applicable to Persons in the European Union and European Economic Area
This section 5.3 applies only to those who reside in the European Union or European Economic Area (EEA).
5.3.1 Transfers of the information outside of the European Economic Area
We are a company located in the United States of America, therefore we may process your Personal Information outside of the European Economic Area. We do this in the ordinary course of our business.
Further details on the steps we take to protect your personal information in these cases are available at any time upon request by contacting [privacy at red9.com].
5.3.2 Your rights
As a data subject under EU data protection laws, you have specific legal rights relating to the Personal Information we collect from you. We will respect your individual rights and will deal with your concerns adequately.
- Right to withdraw consent: Where you have given consent for the processing of your Personal Information, you may withdraw your consent at any moment.
- Right to rectification: You may obtain from us the rectification of your Personal Information. We make reasonable efforts to keep Personal Information in our possession or control which is used on an ongoing basis, accurate, complete, current, and relevant, based on the most recent information available to us.
- Right to restriction: You may require us to restrict the processing of your Personal Information, if:
- you contest the accuracy of your Personal Information, for the period we need to verify the accuracy;
- the processing is unlawful and you request the restriction of processing rather than erasure of your Personal Information;
- we no longer need your Personal Information, but you require it for the establishment, exercise, or defense of legal claims; or
- you object to the processing while we verify whether our legitimate grounds override yours.
- Right to access: You may request information regarding Personal Information that we hold about you, including information as to which categories of Personal Information we have in our possession or control, what they are being used for, where we collected them (if not from you directly), and to whom they have been disclosed, if applicable.
We will provide you with a copy of your Personal Information upon request. If you request further copies of your Personal Information, then we can charge you with a reasonable fee that we base on administrative costs.
If we transfer your Personal Information to a country outside the EU and EEA, you have the right to request information about the safeguards in place for our transfer of that data to the receiving country.
- Right to portability: You have the right to receive Personal Information that you have provided to us, and, where technically feasible, request that we transmit such Personal Information to another organization.
You have these two rights if:
- we process your Personal Information by automated means;
- we base the processing of your Personal Information on your consent, or our processing of your Personal Information is necessary for the execution or performance of a contract to which you are a party;
- you provided your Personal Information to us; and
- the transmission of your Personal Information does not adversely affect the rights and the freedoms of other persons.
- You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format.
Your right to receive your Personal Information must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your Personal Information to another organization also involves the transmission of the personal data of other (non-consenting) individuals.
Your right to have your Personal Information transmitted from us to another organization is a right you have only if such transmission is technically feasible.
- Right to erasure: You have the right to request that we delete the Personal Information we process about you. We must comply with this request if we process your Personal Information, unless the data is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation that binds us;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
- for the establishment, exercise or defense of legal claims.
- Right to object: You may object – at any time – to the processing of your Personal Information due to your particular situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. In this event, we shall no longer process your Personal Information, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise, or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your Personal Information; otherwise, we will only restrict it.
You may always object to the processing of your Personal Information for direct marketing purposes, even if it was based on our legitimate interest for any reason. If the marketing was based on your consent, you can withdraw consent.
- Right to lodge a complaint: You can lodge a complaint to the data protection authority in your Member State or to the data protection authority in the Republic of Ireland.
- Time period: We will try to fulfill your request within 30 days, which may be extended due to specific reasons relating to the specific legal right or the complexity of your request. In all cases, if this period is extended, we will inform you about the cause and anticipated length of the extension.
- Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.
- No identification: In some cases, we may not be able to look up your Personal Information due to the choice of identifiers provided in your request. In such cases, where we cannot identify you as a data subject, we will not be able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
- Exercise your legal rights: In order to exercise your legal rights, please contact us in writing (including electronically) at the contact details provided below.
6. Contact Information
Please direct your questions regarding the subject matter of data protection and any requests in the exercise of your legal rights to the following:
[privacy at red9.com]
Red9.com, 11720 Amber Park Drive, STE 160, Alpharetta, GA 30009.
We will investigate and attempt to resolve any request or complaint regarding the use or disclosure of your Personal Information.
If you are not satisfied with our reply and you are from the European Union, you may also make a complaint to the data protection authority, as indicated in section 5.3.2(h) above.
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