Privacy Policy

Last Updated: April 21, 2019

Reddul respects the privacy of its users. This Privacy Policy (“Privacy Policy”) informs you about our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information.


About Us

We are Reddul, Inc. (“Reddul”, “us”, “we” or “our”),

operates the https://reddul.com/ website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://reddul.com/


About the Reddul Services

We provide users (“you”, “your”) with services, delivered via the Reddul website (currently located at http://www.reddul.com), (the “Site”), the Reddul mobile
applications, and/or any other platform or media through which we may make such services available from time to time, that allow you to explore the Internet, find new websites that may be of interest to you, receive recommendations of websites from Reddul, and join a community of individuals with similar tastes and interests
(collectively, the “Services”).


About This Privacy Policy

This Privacy Policy informs you of Reddul’s policies and practices regarding the collection and use of information you submit to us or which we collect about you through our Services and informs you of options that you have to control or restrict the availability and use of your information. Wherever you reside or from whichever country you submit your information, you consent to our use of your information, consistent with this Privacy Policy over the World.


Changes to This Privacy Policy

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so please review it periodically. If you continue to visit this Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes and such use indicates such consent.

 

Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Reddul will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

 

New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Reddul will endeavor to comply with the law or contract.


Your Account

You may choose to create a Reddul account or you may use the Services without creating an account. Either way, we consider you a “User” of the Services. You may also have created an account through one of Reddul’s connected social networking communities (“Partner Communities”). Once you have created an account you may choose to add a photo or other information to your profile (the “Reddul Profile”).


Why Does Reddul Collect Information?

We want to give our Users the best possible experience, personalized for each User. We collect information to improve our Services, features and content, to administer your use of our Services, and to deliver content that we determine may be of interest to you.


Some Terms We Use in This Privacy Policy

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Reddul or to which Reddul discloses Personal Information for use on its behalf.

“Non-Identifying Information” means information that does not permit the identification of an individual person, such as information that you provide as part of registration and personalization of your Reddul account, or certain information that Reddul collects through its Partner Communities. Some Non-Identifying Information could be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified.

“Log Data” is derived by our servers automatically as you engage with the Services, which record information that your browser or mobile device sends whenever you interact with the Service.

“Personal Information” is any information relating to an identified or identifiable natural person
(“Individual”).

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise
making available, alignment or combination, restriction, erasure, or destruction.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Reddul or Reddul’s Agents.


What Information Does Reddul Collect?

Reddul will collect only that Personal Information which is relevant for the purposes of Processing that information as described in this Privacy Policy.

Personal Information. When you create a Reddul account or connect through our Partner Communities, we will collect your e-mail address, gender, year of birth and specific or general location. If you register for our Services via a Partner Community, we will obtain certain Personal Information you have provided to the Partner Community (such as your name, profile picture, e-mail address, date of birth and specific address or general location). If you enable interoperability with a Third Party application, additional Personal Information that you have provided to that Third Party application may be collected and/or you may specifically authorize Reddul to access certain information from such Third Party application. The information we obtain may depend on the privacy settings you have with the Partner Community or Third Party application and the information obtained may not be visible in your account. If you personalize your Reddul account, we will also collect any information you provide, such as your full name, your photo or avatar and any optional information you decide to supply about yourself and your interests. We will first seek your specific permission before we gain any access to your contacts should you wish to enable sharing through the Services.

Non-Identifying Information. We also collect some Non-Identifying Information about you and your interests as you navigate through and interact with our Services.. We may also receive Non-Identifying Information about you and your interests from other sources like Third Parties that add to their websites Reddul widgets or Reddul badges.

Log Data. When you interact with the Services our servers automatically record information that your browser or device sends. This Log Data may include information such as your computer’s IP address, browser type, and operating system, your mobile device identifier, the time of day of your access, your general physical location or your more specific location if you are connecting through your mobile device, and other analytics that help us deliver and monitor the effectiveness of our Services.

Information You Provide. When you enter any other information into any postings or comments, we may collect this information.

Contacting us. When you leave us feedback or write to us directly, we will collect any information
that is contained in your feedback or comment form, which will include your e-mail address and other information that you may submit to us for reference or reply.


Does Reddul Use Cookies or Other Tracking Methods?

On the Reddul Site, Reddul and Third Parties that provide content, advertising, or other functionality on our
Services may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to
automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our Sites, Services, applications, messaging, and tools, and to recognize you across devices.

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their
    preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
  • Social Media Widgets. Our Site includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
  • Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit
    http://www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary. We may use Technologies that are necessary to the operation of our Site, Services, applications, and tools. This includes technologies that allow you access to our Site, Services, applications, and tools; that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
  • Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site, Services, applications, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, Services, applications, or tools;
  • Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Site, Services, applications, or tools. This may include identifying you when you sign into our Site or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Site;
  • Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including advertisements relevant to your interests, on our Site or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

Your Options: Most browsers are initially set up to accept cookies and tracking pixels. You can reset your browser to refuse all cookies or to indicate when a cookie is being set. Instructions to remove persistent cookies can be found through outside resources. Mobile devices may contain settings that allow you to disable tracking, analytics and/or location data. Be aware, however, that if you choose to disable cookies or opt out of tracking or disengage similar features on your mobile device, some areas of the Services may not be optimized for your use, you may not be able to access any or all of the functionality of the Services, and your experience using the Services will be limited.


How Can You Edit or Remove Your Personal or Other Information?

You may choose to edit the Personal Information that is in your Reddul account so that different or less
information is available to be viewed. To remove other Personal Information that may not be visible in your account, you may contact us here with a request that we delete your
Personal Information from our database or remove other information that you no longer wish to include as part of the Services. We will use commercially reasonable efforts to honor your request.

We may retain an archived copy of your records as required by law or for legitimate business purposes. When you receive messages from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “unsubscribe”. We may, however, still send you administrative messages regarding the Services. If a child between the ages of 13 and 18 wishes to erase or delete any information that he or she has included or shared via the Services, please contact us here and we will promptly comply.


How Does Reddul Use Information Internally?

To Provide Products, Services, or Information Requested. Reddul may use information about you to fulfill
requests for products, Services, or information, including information about potential or future Services, including to:

  • o Generally manage Individual information and accounts;
  • o Respond to questions, comments, and other requests;
  • o Provide access to certain areas, functionalities, and features of Reddul’s Services;
  • o Contact you to answer requests for customer support or technical support.

Administrative Purposes. Reddul may use Personal Information about you for its administrative purposes, including to:

  • o Measure interest in Reddul’s Services;
  • o Develop new products and Services;
  • o Ensure internal quality control;
  • o Verify Individual identity;
  • o Communicate about Individual accounts and activities on Reddul’s Services and systems, and, in Reddul’s discretion, changes to any of our policies;
  • o Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • o Process payment for products or services purchased;
  • o Process applications and transactions;
  • o Prevent potentially prohibited or illegal activities;
  • o Enforce our Terms.

Marketing. Reddul may use Personal Information to provide you with materials about offers, products,
and Services that may be of interest, including new content or Services. Reddul may provide you with these materials by or email, as permitted by applicable law. Such uses include:

  • o To tailor content, advertisements, and offers;
  • o To notify you about offers, products, and services that may be of interest to you;
  • o To provide Services to you and our sponsors;
  • o For other purposes disclosed at the time that Individuals provide Personal Information; or
  • o Otherwise with your consent.
  • o You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in “How do I Opt Out?” section below.

Research and Development. Reddul may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Reddul may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional
activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Services via Mobile Devices. From time to time, Reddul may provide Services that are specifically
designed to be compatible and used on mobile devices. Reddul will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Reddul’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Reddul may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other
devices. These tools may transmit Personal Information to Reddul to enable Individuals to access Accounts and to enable Reddul to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Reddul may use Personal Information or non-identifiable information transmitted to Reddul to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Reddul provides.

Other Uses. Reddul may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

You agree that Reddul is free to use the content of any communications submitted by you via the Services, including any profile photo, submissions and collections of articles, for any purpose including developing, manufacturing, and/or marketing goods or Services. Some examples of these uses include posting to our community blog (community.Reddul.com) and social media such as Twitter and Facebook, subject to the applicable terms governing use of those social media services.


When Does Reddul Share Information with Others, and with Whom?

Sharing Via Your Reddul Account. The information provided in your Reddul account that you select to be
publicly displayed will be public information and any User will be able to view it. You may edit or hide
information in your profile at any time so that it is no longer accessible to the public, but even if you
delete your data, it may continue to exist within or displayed via the Services and/or be shared by other Users. Also, when you enter any information (including Personal Information), into postings or comments via the Services, this information, may be available to some, a subgroup of, or even all Users of the Services, depending on how and where this information was posted by you and with whom you have elected to share the posting or comment.

Aggregate Information & Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with Third Parties for industry analysis, demographic profiling, advertising, marketing and other purposes relating to our Services. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Providers. We may employ Third Party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform maintenance and research services, or to assist us in analyzing how our Services are used (such as infrastructure providers, database management, web or mobile analytics and improvement of the Services’ features).

Business Transfers & Affiliates. Reddul may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Reddul may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Reddul. Reddul requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Reddul provided them.

If Reddul or the assets of Reddul are acquired by another company, or if Reddul is involved in financing due diligence processes or transition of service to another service provider, then we may transfer your information, including Personal Information, in connection with that acquisition or sale or transaction and Reddul will direct the recipient of this information to assume the rights and obligations described in this Privacy Policy.

We also may share your information with affiliates in the same corporate family as Reddul.

Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, we may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Reddul related websites within their networks. This practice is commonly referred to as “interest-based advertising”
or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in the “How do I Opt Out?” below.

Compliance with Laws & Law Enforcement. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to:

(i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena;

(ii) respond to your requests;

(iii) protect your, our or others’ rights, property, or safety;

(iv) to enforce Reddul policies or contracts;

(v) when we believe disclosure is necessary or appropriate to prevent physical harm
or financial loss or in connection with an investigation or prosecution of suspected or actual illegal
activity; or

(vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.


How Do I Opt Out?

General. You have the right to opt out of certain uses and disclosures of your Personal Information.
Where you have consented to Reddul’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us here. Even if you
opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

Email. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Reddul and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

Mobile Devices. Reddul may occasionally send you push notifications through our mobile applications and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Reddul may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain
web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/‌managing/‌opt_out.asp,
or www.youronlinechoices.eu and www.aboutads.info/‌choices/. You can also choose not to be
included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.


How Can I Access, Rectify, Erase, and Restrict My Information?

You may inquire as to whether Reddul is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail here or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Reddul. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Reddul makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Reddul is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Reddul determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Reddul will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.


Where and How Long Will Information Be Collected and Stored?

Reddul is located in the United States. Accordingly, Personal Information we collect may be transferred to and stored in our servers or those of Third Parties that act on our behalf (such as hosting providers) in the United States or other countries outside of the European Economic Area. By using the Services you agree to such collection, transfer and storage outside of the European Economic Area or other territories where the information may have been collected.

Reddul retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.


How Secure Is the Information?

You should be aware that while we endeavor to take industry standard administrative, physical and technological measures to maintain the security of your Personal Information, we are not able to fully eliminate all security risks or potential breaches.

By using the Site and Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site and Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.


What Is the Policy Towards Children?

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Reddul does not knowingly collect Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. Reddul urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us here. If we learn that we have collected any Personal Information from
children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s Account.


California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties.


What Policies Apply to Third Party Websites, Services and Applications?

The Services may contain links or integrations to Third Party applications, websites or services, and also may be accessed via Third Party applications, websites or services. Our display within the Services of links or referrals to other websites, services and applications does not signify our endorsement of such other websites, services or applications or their content. We have no control over, do not review, and cannot be responsible for these outside websites, services or their content. This Privacy Policy does not govern your visits to these other websites or services, and your access is entirely at your own risk. These other services and applications may set their own cookies on users, collect data, or solicit personal information. You should refer to any privacy policies on such services and applications to understand how your information may be collected and used, and should choose appropriate settings for sharing your personal information before proceeding to any
integration with a Third Party service or application.