1. INFORMATION WE COLLECT

1.1 Information We Obtain About You

We receive and store any information you enter on the Service or provide to us in any other way. You can choose not to provide us with certain information, though you may not be able to take advantage of many Service features. The personal information you provide may be used for such purposes as responding to your questions or requests, customizing the content you see, and communicating with you about new Service features. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Service, we may collect such information into a file specific to you. You agree that we may use your personal information to contact you as provided herein, though our intent is that email is the only channel we will use to contact you without your consent Information we receive directly from you, we receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following::

• Contact information, such as name, phone number, and email and postal address
• Account information, such as online password and other log-in details used to access RD Global products and services
• Payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third-party payment processor on our behalf
• The geolocation of your mobile device if you consent to the collection of this data
• Other personal information contained in content you submit to us, such as through our “Contact Us” feature or customer support tools on our websites or mobile apps

1.2 Information We Obtain by Automated Means

Browsing the Site does not require you to register for an account or provide any personal information to us. In general, RD Global will gather some generic information automatically. This generic information may include the internet address assigned to your computer, the number and frequency of visitors to the Site, the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), and your computer browser information. Generic information does not reveal the identity of the visitor. This type of aggregate data may enable us to figure out how often users use parts of the Service, help us determine customer service and Site needs, and do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community. RD Global may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. As part of this use of information, we may provide aggregate information, not information about you personally, to our partners about how our users, collectively, use our Service. We use analytics to help analyze how our users use the Services. Google Analytics uses cookies to collect information such as how often our users visit the Services, what pages they visit, and what other sites they used prior to coming to the Services. We may use the information we get from Google Analytics to improve our Services or to send you promotional messages about our Services. Google Analytics collects the IP address assigned to you on the date you visit the Services, but not your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with any personally identifying information. Although Google Analytics plants a persistent Cookie to identify you as a unique user the next time you visit the Service, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Service is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners. Information we automatically collect when you use our Service. Some Personal Data is automatically collected when you use our Service, such as the following:

• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
• Location information (e.g. IP address, zip code)
• Log data (e.g. access times, hardware and software information)

1.3 Cookies

When you visit the Site, we may send one or more “cookies” to your computer hard drive through your Web browser. A cookie is a small file containing a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Any use of cookies by us will be solely for the purposes of improving the quality of access to the Site by storing user preferences, and tracking user trends, such as how people use the Site, and their Site access preferences. Cookies tell us how and when pages in our Site are visited and by how many people. We use cookies to allow you to enter your login information less frequently. To the extent RD Global uses cookies, such cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your username or e-mail address is. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to reenter your password or login information more frequently. RD Global visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Site. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. We recommend that you leave the cookies activated, however, because deleting cookies may reduce the functionality of RD Global. We do not control the use of cookies by third parties.

We process Personal Data to operate, improve, understand and personalize our Service. For example, we use Personal Data to:

• Provide our products and services to you
• Establish and manage your RD Global account and profile
• Process orders
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Service
• Personalize website content and communications based on your preferences
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms of Service

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties. Examples of these legitimate interests include:

• Operation and improvement of our business, products and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

2.1 Third-Party Analytics Services

We use third-party web analytics services on our websites and mobile apps. The service providers that administer these services use automated technologies to collect data (such as email and IP addresses) to evaluate use of our websites and mobile apps.

2.2 Online Tracking and Interest-Based Advertising

On our websites, we may collect information about your online activities to provide you with advertising about products and services tailored to your interests. This section of our Privacy Notice provides details and explains how to exercise your choices.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

Our websites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/.

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• Payment processors
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers
• Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Other users (where you post information publicly or as otherwise necessary to affect a transaction initiated or authorized by you through the Service)
• Social media services (if you interact with them through your use of the Service)
• Third party business partners who you access through the Services
• Other parties authorized by you

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.
Last, we share Personal Data with our affiliates or other members of our corporate family.
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: contact@rdglobalinc.com

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. RD Global will be the controller of your Personal Data processed in connection with the Service.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at contact@rdglobalinc.com

We treat data as an asset that must be protected against loss and unauthorized access. We use industry-standard Secure Socket Layer (SSL) software to protect the security of your personal information during transmission, which encrypts all of the information you input. All personal information collected from other Platform Services that you provide through the use of the Service is stored securely. Only employees who need personal information to perform a specific job (for example, a customer service representative) are granted access to it. All of our employees are kept up to date on our privacy and security practices.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example, we may be forced to disclose personal information to the government or third parties under certain circumstances or third parties may unlawfully intercept or access transmissions or private communications.

6.1 Policies for Children

We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at contact@rdglobalinc.com

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email contact@rdglobalinc.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
• Portability: You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about RD Global’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Policy changes on this page. We may amend this Privacy Policy at any time by posting the amend terms on the Site. All amended terms shall automatically be effective thirty (30) days after they are initially posted on the Site. Each version of this Policy will be identified at the top of the page by its effective date.

If you have any questions about this section or our data practices generally, please contact us by e-mail at contact@rdglobalinc.com