Last Updated: December 16th, 2020
RedCircle Technologies, Inc.
2093 Philadelphia Pike #4216
Claymont, DE 19703
What Information We Collect
Sign Up Information. When you sign up to create an account with RedCircle, we collect and retain certain information that you can be used to identify you (“Personal Data”), including, in the case of account creation: your first name, last name, phone number, and email address.
Information You Voluntarily Provide. You may also provide certain information to us when you use the Services, including when you contact us for support or other inquiries, or provide feedback about the Services. This information may include your name, email address, phone number, postal address, billing address, and other information that may relate to you or identify you. We will also collect any information you provide to us when you send us emails with queries, feedback, or for any other reason.
Financial Information. We may request certain financial and payment-related information from some Users, depending upon which of the Services they choose to utilize. From podcast creators who choose to utilize our Monetization Services (see Terms of Service), we may request date of birth, government identifier, home address, bank routing and account numbers, debit card number, and employer identification number. This information is sent directly to our payment processor, to facilitate payments to you, and RedCircle does not obtain or store this data. From Users who choose to donate to podcasts and from advertisers who use our advertising services to promote goods and services in podcasts, we may request a credit card number, expiration date, CVC number, postal code, and the name on the card. This information is sent directly to our payment processor, to facilitate payments, and RedCircle does not obtain or store this data.
Location Information. When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or, when interacting with our mobile application, by accessing your mobile device’s GPS or location services, which may provide more precise geolocation information, if you enable location services on your device.
Information Sent by Your Device. We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to IP Address, user agent information, network and connectivity information, device identifiers, advertising identifiers, language preferences, user settings, software and operating system names and versions, hardware models, as well as other information about your use of our Services.
Listener Information. We also collect a limited set of information related to listeners of the podcasts hosted by RedCircle, irrespective of which podcast listening app or service you utilize to listen to podcast. This information includes: your IP address, user agent (i.e. operating system and which app or browser you use to listen to podcasts), and podcast listening information (e.g. the podcasts episodes that you download or listen to, which parts of the podcasts are heard or skipped, and time stamps associated with listening).
Third Parties. We may also obtain information about Users from third parties, such as affiliates, joint marketing partners, and lead providers.
“Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an email).
“Log Data” means certain information about how a User uses our Services. Log Data may include information such as a User’s IP address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address and other information to generate information about how our Services are used and to detect fraud.
How We Use the Information.
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:
- Providing our Services, including podcast hosting and analytics services, podcast monetization, facilitation of donations, advertising placement and attribution.
- Communicating with Users and providing customer support in relation to the Services.
- Resolving disputes, responding to queries, collecting and processing payments fees (as applicable) and troubleshooting problems.
- Managing our everyday business needs, including the following activities: auditing, administration of the Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our Terms of Service, or to comply with applicable laws or regulations.
- Customizing your experience and otherwise measuring and improving our content and Services.
- Sending you relevant emails and communications (including keeping you informed about our products, offerings, and any promotional offers) that might be of interest to you. (In the event that we use your personal information to market to you, you will be able to opt-out of such uses).
- Enforcing our agreements, terms, conditions, and policies, and sending you notices and alerts.
- Better understanding our Users’ interests, behaviors, and demographics.
- We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent. Any communication or material you transmit to us via e-mail or otherwise, including any data, questions, comments, chats, phone calls, suggestions or the like (though excluding your personal information) will be treated as non-confidential and non-proprietary.
Information that We Share with Third Parties.
We will not share any Personal Data that we have collected from or regarding you except as described below:
- Services Providers and Business Partners. We may engage third-party service providers to help us administer, provide, and improve the Services, including but not limited to the following types of partners: web hosting providers, cloud hosting providers, fraud detection services, fulfillment service providers, and customer support partners. These third-party services providers will have access to your Personal Data for the purpose of performing services on our behalf. For example, we may share your Personal Data with our cloud hosting providers (for example, Amazon Web Services) as part of our utilization of their hosting Services.
- At Your Request. We may share information about you with third parties in the event that you request we do so, for example, with companies offering promotions or offers through our Site our Services, if you are interested in that offer and request that we share your information.
- The General Public. We may share with the general public information that you submit in public forums, for example blogs, social media, comment sections on the website. For example, audio content and episode descriptions submitted by podcast creators are made available to the public.
- Other Third Parties. We may share anonymized or aggregated data we collect from the use of the Services, including but not limited to de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other Users.
- Our Subsidiaries and Affiliates. We share information with our corporate subsidiaries and affiliates to help us provide our Services.
- With Your Consent. There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent
- Information Shared with Web Analytics Services Providers. We may use some or all of the following analytics services:
- Google. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how Users engage with our Site and Services. For more information about Google Analytics, please visit 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.
- Information Disclosed in Connection with Business Transactions. Information that we collect from our Users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.
- Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
- With Avertising Partners and Social Media. Your personal data may be shared with certain advertising partners and social media partners who we allow to place cookies (or similar technology) on our Site as necessary to their provision of various services, including but not limited to ad attribution, ad placement, audience measurement, social sharing, and site analytics. Additionally we have relationships with advertising partners, such as supply side platforms, who assist us in placing advertisements within the podcasts heard by our listeners. We may also allow these partners to obtain limited information about our listeners, including but not limited to IP address and user agent, in order to provide their advertising services.
We offer you choices regarding the collection, use and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
Opt-out of Ad Tracking. You can opt out of the collection and use of your information for ad targeting by going to http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to limit collection through the Site, by configuring the settings on your browser, or by using cookie blocking extensions in your browser.
Modifying Your Information. You can access and modify the Personal Data associated with your account by sending an email to firstname.lastname@example.org. If you want us to delete your Personal Data or your account, please contact us at email@example.com with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Non-Affiliate Marketing. We do not currently share Personal Data with third parties seeking to market their own products or services to our Users. However, in the event that the company would begin sharing such information for such purpose, Users will be allowed to opt out of such sharing.
Additional Choices. As discussed below, additional choices may be available to you under the California Consumer Privacy Act. You can learn about those in our California Privacy Notice.
Responding to Do Not Track Signals. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
The Security of Your Information. We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
Data Retention. We need to retain the information you provide us in order to provide our Services, and we retain such information for as long as you maintain your account, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that it is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit or debt on your account or an unresolved dispute, ongoing investigation (e.g. for fraud or misuse), or we believe that we may be required to retain your account for legal reasons. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing Users' safety and security. For example, if we shut down a User's account because of security or fraud incidents, we may retain certain information about that account to prevent that User from opening a new account in the future.
International Transfer. Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Data to us, we may transfer your Personal Data to the United States and process it there.
Our Policy Toward Children. Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete such information from our files as soon as possible.
Your California Privacy Rights. If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our California Privacy Notice addresses these rights.