Privacy Policy Red River Technology LLC

 

This Privacy Policy (the “Privacy Policy“) both (i) governs how we collect, use, and treat personal information that you provide to Red River Technology LLC (“Red River,” “we,” “our“, or “us“) through our website at http://www.redriver.com (the “Website” or “Site“), while using the services and information available via the Website or otherwise (collectively, the “Services“) (the Services, together with our Website, are referred to as the “Platform“), or that you otherwise provide to us, and (ii) establishes certain rights and obligations with respect to your personal information and use of our Platform.

Our Platform contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.

1.     Your Consent to this Privacy Policy.

You indicate your consent to this Privacy Policy in different ways, depending on your relationship with us. The procedures for consenting to this Privacy Policy are less formal if you are a casual visitor to our Site (a “Guest User“) and more formal if you are, or are seeking to become, a registered user (a “Registered User“).

1.1      Consent by Guest User.

We have structured our Website so that, as a casual Website visitor, you are able to come to our Website and review selected information about our Services without providing us with any Personal Information. By accessing and using our Platform as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

1.2      Consent by Registered Users.

In order to participate in the Services, you must: (i) complete the registration process at our Platform; (ii) be age eighteen (18) or older; and (iii) indicate your consent to this Privacy Policy in the manner we specify during the registration process.

1.3      Consent by User Acting in a Representative Capacity.

If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization“), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.

1.4      Right to Withdraw Consent.

You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Choices Regarding Your Personal Information; Opting Out).

2.     The Information We Collect.

The information that we collect about you falls into certain categories as further described in this Section 2 (The Information We Collect). This information consists of the following:

2.1      Personal Information.

We collect certain information that identifies you as an individual (collectively, “Personal Information“). The Personal Information we collect may include the following:

  • Your name, email address, and password;
  • Your other contact information including a physical address, phone number, and fax number;
  • Any information or feedback you provide in communications with us through our Website or via social media, email or our customer call center; and
  • The agency or organization that you represent.
2.2      Online Activity Information.

We also collect technical and device-related information through our Website and third party analytics tools that we use (collectively, “Online Activity Information“). Sometimes Online Activity Information can be associated with your Personal Information, in which case we will treat it as Personal Information (as described in Section 2.4 (Treatment of Combined Information), otherwise we consider, and treat, Online Activity Information as Anonymous Information.

2.3      Anonymous Information.

Our Platform also collects, processes, and/or uses information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information. We use Anonymous Information for our business operations, for example, to engage in marketing and other activities in a manner that protects our customers. Since Anonymous Information does not include Personal Information, it is outside the scope of this Privacy Policy.

2.4      Treatment of Combined Information.

To enable us to better understand the characteristics of our users and/or to provide Services tailored to your needs, we may link your Personal Information with Online Activity Information associated with you or other Anonymous Information. If we combine or associate Online Activity Information or other Anonymous Information with your Personal Information, then we will treat the resulting combination as Personal Information.

3.     How We Collect this Information.

We collect the above information through the following means and technologies:

3.1      Registration.

In order to provide you with certain Services, we need to collect Personal Information, including that specified in Section 2.1 (Personal Information). For example, when you register an account with our Storefront Service, you must provide a variety of Personal Information to us in connection with creating a user account.

3.2      Contacting Red River.

You can contact us with questions or comments – for example, you can contact us to learn more about Red River’s supplier diversity program and the various contract vehicles, such as the California Multiple Award Schedules, in which we participate. In order to communicate with us, you must provide certain Personal Information.

3.3      User-Generated Content.

We may give you the ability through the Platform to engage with us and others in public exchanges, and this may include opportunities for you to provide comments, reviews, recommendations, and other input via the Platform (collectively, “User-Generated Content“). Please understand that, if you include Personal Information in User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use the Personal Information. We are not responsible for Personal Information you decide to include in User-Generated Content, and we will not take down, remove, or edit User-Generated Content, except as required by applicable law. If you include in your User-Generated Content any Personal Information relating to others, you represent that you have full permission and authority to do so.

3.4      Requesting a Quote.

You can request a quote directly from Red River via the Site. To do so, you must provide certain Personal Information, such as your name, the agency or organization that you represent, your mailing address, other specified contact information, and a description of the product for which you are requesting a quote.

3.5      Newsletters and Special Offers.

You can provide us with Personal Information so that we can send you (i) newsletters about Red River, our Services, and information about issues that we believe may be of interest to you, and (ii) special offers about our products and Services.

3.6      Beacons and Tags.

The Platform may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Platform have been visited or to measure the effectiveness of searches that users perform on our Platform. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, including Online Activity Information and, in certain instances, Personal Information.

3.7      Device Identifiers; Logs; IP Addresses.

To determine whether your device is supported by our Platform, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Platform, as well as the presence of any software that our Platform may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Online Activity Information.

3.8      Cookies.

A cookie is a small amount of data that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services. Cookies alone are typically Online Activity Information.

3.9      Click-Throughs.

We may send email messages or display links that use a “click-through URL” linked to our Platform or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information, including Online Activity Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

3.10    Other Technologies and Data Sources.

We currently do not augment the Personal Information that you provide to us with data from other third-party sources, such as privately held marketing or analytics databases. We do not, for example, link your Personal Information with third-party demographic information (such as age, sex, household income, job industry, or job title). If we later choose to use these data sources, or technologies other than those listed above in this Section 3 (How We Collect this Information), we will treat any information we collect or generate in that manner in full accordance with this Privacy Policy.

3.11    Collection of Personal Information Offline.

We may ask you to provide us with Personal Information via offline interactions. Personal Information we collect in this manner may include, for example, your name, address, email address, and other identifying information. If you provide information to us at our request, then we will strive to provide you with either verbal and/or written notice of this Privacy Policy upon your request for a copy of the Privacy Policy. We treat any information that you provide to us as Personal Information under this Privacy Policy.

4.     How We Use The Information We Collect.

We use the information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with the terms of this Privacy Policy. More specifically, we use the information we collect for the following purposes:

  • To provide you with the Services you request (on the Website, by phone, or otherwise), including use of our Website, to create and manage Registered User accounts, and to communicate with you regarding our Services;
  • To allow you to post User-Generated Content;
  • To respond to your inquiries;
  • To customize and enhance your use of our Website and Services, such as by personalizing your experience with us;
  • To provide communications that might interest you, including marketing messages and to inform you of products and services that we think would be appealing to you, whether the products or services are provided by us or by others, and whether the products or services are available via our Site or via a third party;
  • To verify your identity and to securely process your purchases or other requests for Services;
  • To perform analytics, quality control, market research, and to determine the effectiveness of our Site, promotional campaigns, to improve our current products, Services, and Site, and develop new products and services;
  • To perform internal administration, auditing, operation, and troubleshooting for our Site and Services; and
  • To share the information with third parties strictly as permitted in Section 6 (How We Share this Information) below.

In addition to the uses specifically identified above, there may be instances where you request information and Services from us that are not described in this Privacy Policy. In our discretion, we can use information that you submit in order to provide such information and Services.

5.     Other Essential or Internal Uses of Information.

We may also use the information that we collect as we believe to be necessary or appropriate for certain essential purposes, including:

  • To comply with applicable law and legal process;
  • To respond to requests from public and government authorities, including public and government authorities;
  • To detect, prevent, or investigate potential security incidents or fraud;
  • To facilitate the functionality of our Platform;
  • To enforce our terms and conditions;
  • To protect our operations or those of our affiliates;
  • To protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others; and
  • To allow us to pursue available remedies or limit the damages that we may sustain.
6.     How We Share this Information.

We value your privacy, and we share the information we collect only in the manner set out below.

6.1      Our Service Providers.

We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, data analysis, order fulfillment, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information, Online Activity Information, and Anonymous Information as applicable. We will seek to only provide third parties with information so that they can perform their required functions.

6.2      Questions of Harm; Legal Process.

We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary: (i) o comply with legal process; (ii) to protect and defend our rights and property, including the Platform and associated content; (iii) to protect against misuse or unauthorized use of our Services; (iv) to protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and (v) to cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

6.3      Corporate Transactions.

We shall be entitled to transfer information that we collect (including Personal Information) to a third party in connection with or in contemplation of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personal Information with protections that are compatible with those set out in this Privacy Policy.

6.4      Our Affiliates.

We may choose to rely on and share the information we collect with our affiliates. By “affiliate” we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with, Red River Technology LLC. Our affiliates will be bound by the terms of this Privacy Policy.

7.     Information to Third Parties.

As further set out in our Terms of Use, our Site includes links to third party websites offering services that augment those services offered on our Site. For example, when you submit information in connection with applying for a job at Red River or when you submit payment information in connection with purchasing a product, you are providing information (including Personal Information) directly to third parties, and not to us. Those third parties determine their own data handling practices – any information that you submit to third parties are not governed by this Privacy Policy.

8.     How We Safeguard the Information We Collect.

We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law.

9.     Our Retention of Data.

We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

10.   Accuracy and Minimization of Data.

We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

11.   Your Choices Regarding Your Personal Information; Opting Out.
11.1    Unsubscribing to Marketing Communications.

If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, you can opt out of this Service by either (1) following the “unsubscribe” instructions located near the bottom of each email message, or (2) contacting us as provided in Section 17 (Contact Us).

11.2    Discretionary Account Information.

To allow appropriate control over Personal Information, you can view, change, or update discretionary information that you have previously submitted either by contacting us as provided in Section 17 (Contact Us) below or by accessing your account on our Site (if such functionality is available to you).

11.3    Access, Deletion, and Do Not Sell Requests.
RED RIVER IS CURRENTLY IMPLEMENTING INTERNAL CHANGES TO FULFILL REQUESTS SUBMITTED UNDER THIS SECTION 11.3 (ACCESS, DELETION, AND DO NOT SELL REQUESTS). UNTIL SUCH CHANGES ARE COMPLETED, RED RIVER MAY NOT BE ABLE TO FULFILL CERTAIN REQUESTS. RED RIVER WILL NOTIFY THOSE MAKING A REQUEST IF SUCH REQUEST IS IMPACTED BY ONGOING INTERNAL CHANGES. PLEASE NOTE THAT THESE REQUESTS MAY ONLY BE AVAILABLE TO CALIFORNIA RESIDENTS AT THIS TIME.
We provide the following additional rights with respect to your Personal Information:
11.3.1    Copy of Personal Information.

You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you.

11.3.2    Deletion of Personal Information.

You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected.

11.3.3    Do Not Sell Requests.

You may request that we do not share your Personal Information with third parties to be used for purposes not described in this Privacy Policy. The California Consumer Privacy Act refers to this as a “Do Not Sell” request. Red River only seeks to share Personal Information with service providers and others described above for purposes identified in this Privacy Policy, but Online Activity Information or Anonymous Information collected by service providers providing pixels or other third party technologies on our Website could potentially be used by those service providers for their own purposes, some of whom may be able to associate such information with you based on other information they have collected independently (not from Red River). We will endeavor to block such sharing upon request.

11.3.4    Submission of Requests.

You can submit any of these requests by clicking here or by contacting us at 800.796.3060. You may authorize another person (your “Agent“) to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it. Please be advised that these requests are unrelated to an opt-out of marketing communications, which can be done as provided in Section 11.1 (Unsubscribing to Marketing Communications) above.

11.3.5    Response to Requests.

Please be advised that Red River will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please contact us as provided in Section 17 (Contact Us).

11.4    Anonymous Information.

We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.

12.   Advisory Regarding Participation by Children and Teens.

Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.

13.   Relationship to Other Contracts and Terms of Use.

This Privacy Policy must be read in conjunction with any other agreement entered into by you and us that references this Privacy Policy or that otherwise relates to Personal Information (collectively, the “Other Contracts“), as well as our  . The provisions of such Other Contracts are incorporated herein. To the extent that the Terms of Use conflict with this Privacy Policy, this Privacy Policy shall control. To the extent that the Other Contracts conflict with this Privacy Policy or the Terms of Use, the Privacy Policy shall control with respect to our treatment of Personal Information, unless expressly stated otherwise.

14.   Notice of Privacy Rights to California Residents.

The following provisions of this Section 14 (Notice of Privacy Rights to California Residents) apply if you are a California resident.

14.1    Shine the Light Law.

California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.

14.2         California Consumer Privacy Act.

Red River makes the following disclosures regarding the California Consumer Privacy Act:

14.2.1    No Financial Incentives.

Red River does not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. Red River does not offer financial incentives to deter consumers from making such requests. Red River will not discriminate against any consumer for exercising their privacy rights, including those provided by applicable law.

14.2.2    Consumer Reporting.

Red River will endeavor to report consumer request metrics when they become available.

14.2.3    Job Applicants.

If you are a job applicant submitting Personal Information to Red River in connection with an application for employment, you will be provided with a privacy notice regarding how we handle such information as part of the application process.

14.2.4    Questions.

If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please contact us as directed in Section 17 (Contact Us).

15.   Feedback.

We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 17 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.

16.   Changes to this Privacy Policy.

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in applicable law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Platform and/or notifying you of the change via the Platform, email, or other methods. Your continued use of the Platform following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.

17.   Contact Us.

If you have any questions about this Privacy Policy or your dealings with us, then please contact us at dmca.agent@redriver.com.

18.   General Data Protection Regulation.

The following provisions apply to the extent required under the European Union General Data Protection Regulation (“GDPR“), and we expressly disclaim any obligation to extend the rights and obligations set out in this Section 18 (General Data Protection Regulation) to anyone beyond what we are required to do under GDPR:

18.1    Definitions. The following definitions apply to this Section 18 (General Data Protection Regulation):
18.1.1    “Legitimate Interest” means, for purposes of the GDPR, that there is a good reason for the processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term “Legitimate interest” also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Platform, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.
18.1.2    Personal Information” has meaning as set out in Section 2.1 (Personal Information). If you are protected by the GDPR with respect to our use of your information, the term “Personal Information” has the same meaning as the term “personal data” under GDPR.
18.2    GDPR; Our Uses of Information.

We use the information we collect or process, including Anonymous Information, Online Activity Information, and Personal Information, as permitted under applicable law, including where the use is based on: (i) the consent you provide to us at the point of collection as set out in Section 1.2 (Consent by Registered Users); (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party’s Legitimate Interests. More specifically, we use the information we collect for some or all of the following:

Our Use of the Information Bases for Our Use
To provide you with the Services you request and, specifically, to allow us to send you email with information ·  Performance and management of our agreement with you
To allow you to post User-Generated Content ·  Performance and management of our agreement with you·  Your Consent
To respond to your inquiries ·  Performance and management of our agreement with you
To customize your visit to and use of the Platform ·  Our Legitimate Interests
To determine which Services and content (including marketing content) might interest you ·  Your consent·  Our Legitimate Interests
To inform you of products and Services that we think would be appealing to you, whether the products or services are provided by us or by others and whether the products are services are available via our Platform or via some other channel (including channels operated by third parties); this includes information in the form of recommendations and endorsements that we might provide ·  Your consent·  Our Legitimate Interests
To track access to and use of our Platform, and conduct data and other analyses, including anonymization and aggregation of Personally Identifiable Information ·  Our Legitimate Interests
To perform internal administration, auditing, operation, and troubleshooting for our Platform ·  Our Legitimate Interests
To engage in the activities specified in Section 6 (How We Share This Information) ·  Our Legitimate Interests·  Compliance with our legal obligations·  Performance and management of our agreement with you
To evaluate and improve our Platform and our communications, and to develop and test new services and content ·  Our Legitimate Interests
To comply with applicable law ·  Compliance with our legal obligations

 

Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.

18.3    Accessing and Updating Your Information.

If you would like to review, correct, or update the Personal Information that you have provided to us, or if you would like to request an electronic copy of this Personal Information for purposes of transmitting it to another company (to the extent applicable law provides you with this right to data portability) you may make such requests by us as provided in Section 17 (Contact Us).

18.4    Deleting Information.

If you request, we will take reasonable steps to remove your name, email address, and other Personal Information from our databases, within the time frames (if any) set out in applicable law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive our Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by applicable law, and/or data backups and records of deletions. As such, certain Personal Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if any) in accordance with this Privacy Policy and applicable law.

18.5    Objections.

If you object to our processing of your Personal Information, and a request for us to delete this Personal Information is not, in your view, sufficient, please contact us as provided in Section 17 (Contact Us).

18.6    Your “Right to be Forgotten”.

If you are protected by GDPR with respect to our use of your information, upon proper request, we will take the steps set out in GDPR to erase your Personal Information, including information that has may be publicly available via our Platform, such as, for example, Personal Information made publicly available through User-Generated Content.

18.7    GDPR Complaints.

In addition to your right to contact us as set out in Section 17 (Contact Us), if you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

19.   Effective Date.

The effective date of this Privacy Policy is July 1, 2020.

20.   Copyright and Legal Notice.

Copyright © 2020 Red River Technology LLC. All Rights Reserved.

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800.769.3060