This Privacy Policy describes how RedCloud and its affiliated companies ("we," "us," "us," or "RedCloud") as well as our unaffiliated service providers treat personal data that we collect through the Marketplace. Due to the B2B character of the Marketplace (see Terms and Conditions of Use of the Marketplace No. 2), the processing of personal data is the exception. We therefore expect to process only limited personal data. All the terms that are not defined herein shall have the meaning ascribed to them in the Terms and Conditions of Use of the Marketplace (the “Terms”), which Users the Marketplace (“Users”) accept with the use of the Marketplace. The Terms may be updated from time to time at the sole discretion of RedCloud.
To use the Marketplace efficiently and securely, Users must sometimes provide certain personal information/data (“Personal Data”), such as their name and surname, e-mail account, telephone, billing information, and any other information required to provide the Marketplace Services. Therefore, it is required that the information provided is updated, true and accurate. The basis for us to process personal data is the execution by the Users of the Terms and Conditions of Use of the Marketplace, which shall constitute a Contract valid and binding. We may share Personal Data with affiliated companies .
Provision of Personal Data
Users may choose voluntarily , but are not obligated, to provide us with additional Personal Data for business reasons only, such as gender, preferred language(s), city, or other information, such as when Users fill out a form, respond to surveys, participate in promotions, communicate with our helpdesk team, or share their experience with us.
Also, when Users use the Marketplace and Payment Services, we collect personal information automatically. This information may include: (i) Geolocation information, such as precise or approximate location, determined from mobile device's IP address or GPS. We may also collect this information when Users are not using the app if it is enabled through device settings or permissions; (ii) Usage information, such as the pages or content, searches for Products or Services, social media and other actions taken on the Marketplace; (iii) Log Data and device information (including clicking on links to third party applications), IP address, dates and times of access, hardware and software information, unique identifiers, error data, cookie data, and the pages viewed or interacted with before or after using the Marketplace; (iv) Cookies and Similar Technologies, as described in this Privacy Policy; and (v) Payment information, such as the payment instrument used, date and time, payment amount, payment instrument expiration date and billing zip code, address and other details related to the payment, including information about interaction with content and services available through RedCloud
To the extent permitted by applicable law, we may receive additional information about Users, such as references, demographic data, or information to help detect fraud and security issues from third party service providers or partners and combine it with information we have about Users.
Usage of Personal Data
We use Personal Data to improve and develop the Marketplace in order to: (i) enable access the Marketplace and the sale and purchase of Products; (ii) perform analytics, debugging and research; (iii) communicate with by inter alia sending messages, updates, security alerts and account notifications,; (iv) detect and prevent fraud; (v) configure and personalize the experience based on interactions with the Marketplace, the search and purchase history, preferences and profile information, and other content submitted.
We use Personal Data to: (i) create and maintain an environment of trust and security; (ii) detect and prevent fraud, unwanted messages, abuse, security incidents and other harmful activities; (iii) conduct security investigations and risk assessments; (iv) verify or authenticate information provided, perform checks against databases and other sources of information; (v) help resolve disputes; and (vi) comply with the law, respond to lawful requests, prevent harm, and protect our rights.
We use Personal Data to: (i) provide, personalize, measure and improve our advertising and marketing; (ii) personalize, measure and improve our advertising; (iii) administer programs, rewards, surveys, or other promotional activities or events sponsored or operated by the Marketplace or its third party partners; and (iv) analyze characteristics and preferences to send promotional messages, marketing, advertising and other information that we believe may be of interest.
We use Personal Data to: (i) allow or authorize third parties to use the Payment Services; (ii) detect and prevent money laundering, fraud, abuse and security incidents; (iii) conduct security investigations and risk assessments; (iv) comply with legal obligations (such as anti-money laundering provisions), and (v) provide and improve the Payment Services.
Any use of personal data relates to the operation, functionality and improvement of the Marketplace and/or the Services and is necessary for or based on the legitimate interest of RedCloud or the preparation or fulfilment of an agreement with the Users.
Compliance with law
We may disclose information to courts, law enforcement, governmental or public authorities, tax authorities or authorized third parties to the extent we are required or permitted by law or when disclosure is reasonably necessary to: (i) comply with our legal obligations; (ii) comply with a valid legal request or respond to claims made against RedCloud; (iii) respond to a valid legal request in connection with a criminal investigation to address suspected illegal activity, or respond to any other activity that may expose us or any of our other Users to legal or regulatory liability. We will never disclose information without legitimate reason.
Where applicable, we may notify Users of lawful requests unless: (i) notification is prohibited by the legal process itself, by a court order received, or by applicable law, or (ii) we believe that providing notification would be futile, ineffective, cause a risk of injury or bodily harm to a person or group, create, or increase a risk of fraud or harm to RedCloud or Users, or expose RedCloud to a claim of obstruction of justice.
Service Providers
We share Personal Data with affiliated and unaffiliated service providers to help us administer our business, including service providers that help us to: (i) verify identities or authenticate identification documents, (ii) match information against public databases, (iii) conduct background or police checks, fraud prevention and risk assessment, (iv) develop, maintain and debug products, (v) enable the provision of the Services, (vi) provide customer service, advertising or payment services, or (vii) process, manage or evaluate insurance claims or similar claims. These vendors are contractually obligated to protect Personal Data received and have access to it to perform these tasks.
If applicable, where a data recipient is located outside the EEA, RedCloud will implement, if necessary, appropriate data protection safeguards in accordance with applicable law.
Cookies The Marketplace may use a tracking system using "cookies", so that access to information, when moving from page to page, is done more quickly. It also helps in some cases to identify Users, without the need to ask them for their password again and again. These cookies are small files sent by the visited page and are stored on the hard disk of the computer, occupying little space. Users are informed that by using their browser options they can limit or restrict the hosting of these "cookies" as they wish, although it is not advisable to restrict them completely. The system may collect information about preferences and interests. In the event that this occurs, the information will be used exclusively for statistical purposes to improve the services provided on the Marketplace.
Right of access, rectification, or deletion
In relation to their Personal Data the User may exercise their rights of access, rectification or deletion, and request exclusion in accordance with the provisions of the applicable regulations on the subject by sending an email to the help center email address: [support@redcloudtechnology.com]
In case the Personal Data is processed by third parties, a request for rectification, erasure or restriction will be forwarded also to such third parties unless this proves impossible or involves disproportionate effort.
In certain jurisdictions, Users may request that Personal Data be deleted. Please note that if we receive a request to delete Personal Data: (i) we may retain Personal Data as necessary for our legitimate business interests, such as money laundering prevention, fraud detection and prevention, and security enhancement, and (ii) we may retain and use Personal Data to the extent necessary to comply with our legal obligations.
Security
The personal information that Users enter on the Marketplace is completely confidential and we will use commercially reasonable efforts to protect their privacy. When data and numbers corresponding to credit cards are entered, these are encrypted according to security standards, for greater security of the Users.
It is important that Users protect themselves against unauthorized access to their Accounts, passwords and to their computers, devices, and applications. We recommend using a unique password for each Account that is not used on other online accounts. Be sure to log off when finishing using a shared computer. In the event of a breach, the User shall immediately inform RedCloud..
Retention periods Personal Data will be retained only for as long as a User remains registered in the Marketplace and, if applicable, as long as required by statutory retention requirements. If an Account is closed, we will delete all Personal Data we hold about this Account. This excludes data for the fulfilment of our legal and contractual obligations.
Modifications We reserve the right to modify this Privacy Policy at any time, in accordance with applicable law. In that case, we will post the revised Privacy Policy and will also notify Users of the changes using the Marketplace at least thirty (30) days prior to the effective date. If Users do not agree to the modified Privacy Policy, they may cancel their Account. If Users do not cancel their Account prior to the effective date of the modified Privacy Policy, continued use of or access to the Marketplace will be subject to it.
