RedCircle California Privacy Notice

Last Updated: December 16th, 2020

Company Information
RedCircle Technologies, Inc.
2093 Philadelphia Pike #4216
Claymont, DE 19703
privacy@redcircle.com

Privacy Rights Under California Law. If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Those rights include the following:

  1. Right to request disclosure of information collected. You have the right to request details on the specific personal information we’ve collected about you, how it was obtained, whether it was shared or “sold” (within the meaning of the CCPA) to any third parties, and if so why it was shared or sold. We provide detailed information about the types of information we collect (and the extent to which it may be shared) in our Privacy Policy, but you may also contact us directly to inquire about your personal data specifically, as described in the “Contacting Us” section below.
  2. Right to opt out of selling of your personal data. As discussed in the “Information Sharing” section below, there are some specific partnerships we have wherein our sharing of personal data may constitute a “sale” of data, under the CCPA. You have a right to contact us, as described in the “Contacting Us” section below, and opt out of that “selling” of your personal data.
  3. Right to request deletion of data. You have the right to request deletion of your data, unless an exception applies. Examples of exceptions include when we need to keep data to meet legal obligations, detect fraud, investigate reports of abuse or other Terms of Service violations, or fix security issues. Additionally, an exception would apply if we would be unable to provide the services that you signed up for without the data, in which case, you are free to request account deletion and cease use of the services. See more about this in our Privacy Policy. Once we’ve verified your request, we’ll delete your personal information (unless an exception applies) and will direct our service providers to do the same.
  4. Timely response. You have the right to make two free requests in any 12-month period. We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days.
  5. Non-discrimination. We encourage our users to think carefully about their privacy and data sharing habits. And in no way would we ever hold it against one of our users should they choose to exercise the privacy rights granted them by the law. Don’t hesitate to reach out with questions or request.

Contacting Us. To make any inquiries, request, or exercise any of your rights granted under California law, you can contact us at support.redcircle.com, by emailng us at privacy@redcircle.com, or by toll free call at (844) 404-2525. We may need to go through a few verification steps after you reach out, but we’ll help you through that.

Information We Collect. As we address in our Privacy Policy, we collect personal information for a range of purposes, though primarily to allow us to provide and improve the services we provide. In the last twelve months, we have collected the following types of personal information about our users. In some cases the data is provided directly by users. In other cases it was provided by third parties, or obtained through use interaction with our services.

  1. Identifiers, such as your name, email address, IP address, username, or other similar identifiers. We primarily use these identifiers to create your account, maintain security of our services, and communicate with you.
  2. Customer records information, such as telephone number, bank account number, credit card number, or debit card number. We primarily use these types of information to facilitate transactions and payments and to communicate with our users. (This category under CCPA overlaps with other categories.) Note that financial information requested by RedCircle is sent directly to our payment processor, to facilitate payments, and RedCircle does not obtain or store the financial data.
  3. Commercial information, such as payment history, purchase history, donation history, advertising services purchased. We primarily use this type of information to keep track of user transactions and for internal business and financial recordkeeping.
  4. Internet or other electronic network activity information, such as session logs, search history, information about your interaction with a website, application, podcast, or advertisement. We primarily use this type of information to help podcast creators and advertisers understand how our hosting and ad services are performing for them, as well as to improve our own understanding of our services.
  5. Geolocation information, such as your IP address which provides a rough approximation of location, or from your mobile device’s GPS or location services, if you use the app and enable location services on your device. We use this data primarily to understand where our site visitors, app users, and listeners are accessing the services, and in some cases to provide more relevant advertising.
  6. Audio, electronic, visual or similar information, such as audio that our podcast creators upload and provide, and which portions of audio in the podcasts listeners have heard. We primarily keep this data to provide analytics and reports to our podcast creators and advertisers.
  7. Inferences, such as the types of topics that a listener enjoys in choosing and listening to podcasts. We primarily keep this type of data to provide metrics and analytics for podcasters and to promote more relevant content to listeners.

Information Sharing. In the past 12 months, we have disclosed the above categories of information for business purposes, or at your direction, with our service providers, affiliates, and other third-parties. For instance, we share personal data about our users with our data hosting and storage providers. We have agreements with our service providers which limit their ability to use your information and require them to ensure its confidentiality.

As stated above, there are some specific partnerships we have wherein our sharing of personal data may constitute a “sale” of data, under the CCPA. Specifically, your personal data may be shared (in a manner that constitutes a “sale” under the CCPA) 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 share with these partners (in a manner that constitutes a “sale” under the CCPA) certain personal data about our listeners including, but not limited to, IP address and user agent, in order to provide their advertising services to us.

Updates to this Notice. We will update this Notice every 12 months and let you know when we’ve made updates, consistent with our Privacy Policy.