Last Updated: March 9, 2020
Our Policy is intended to explain our privacy practices concerning information about you, including:
Users of the Site and its products and services, and other persons who may be affected by RTX's behavioral advertising and monetization operations, generally fall into three categories:
Information We Collect
The following is a summary of the types of personal and non-personal information we collect from or about you.
RTX Members and Voluntarily Provided Information. We collect personal information on the Site when you attempt to register as a RTX Member or otherwise choose to provide personal information to us. Personal information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: personal name (first and last) and business entity name and/or title with the applicable business entity, as well as your personal and/or business e-mail address, mailing address, business, personal and/or mobile telephone numbers, fax number, PayPal or bank account information (including, but not limited to, account number, routing number and bank location), the last 4 digits of a credit card number, and/or any other information requested on the applicable RTX Member registration form, such as username and password. (For purposes of this Policy, your bank account and other financial information shall be considered "Sensitive Information.") Additionally, we may collect email, phone call, and messenger/chat content if you choose to communicate to us. We also may collect certain non-personal information from Publishers, such as information typically contained in a web server's log files or analytics program including: IP address, browser type and version, operating system, geographic location, referral information, click-stream data, device identifier, unique identifier, HTTP header, including referral URL, etc. (for additional detail about these practices, please see the section below entitled "Individual and RTX Member Behaviors Collected With Cookies, Web Beacons and Other Web Technologies.") Unless otherwise required by applicable law, such as the GDPR, we treat this information as non-personal information. Finally, we collect server and Individual activity information so that we can process and facilitate transactions in, or the awarding or crediting of, Publisher virtual currencies as requested by Individuals and Publishers.
Individuals: Subscription or Survey Information. RTX collects information from Individuals when you voluntarily provide it to RTX or one of its Publishers (for example, by signing up for an email newsletter or through a co-registration offer on a survey), or by other means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a "User Form"). In a User Form, RTX or a third party may offer you incentives in exchange for providing information about yourself, such as name, email address, street address, zip code, telephone numbers, birth date, gender, salary range, education and marital status, occupation, employment information, and personal and/or online interests (together, "User Information"). Completing the User Forms is voluntary and you are under no obligation to provide User Information.
Individuals: Information Collected When You Interact with Advertisements. When you interact with advertisements displayed using our technology, we may obtain certain personal information about you so that we can provide our services. For example, we may collect any information contained in your profile that you have voluntarily agreed to share, including your name, age, gender, and profile picture.
Individuals: Virtual Currency Transactions. In connection with providing our virtual currency monetization platform, through which we offer technology and services to enable Individuals using Publisher Web Properties to earn points or other virtual currencies offered by the Publishers by responding to advertisements, and to facilitate direct payments from such Individuals via credit card, stored value or debit card, PayPal transfer, bank transfer, mobile billing and other payment sources, we may collect personal information, including name; email address; PayPal, credit, debit or stored value card, bank account and similar financial information (for purposes of this Policy, such financial information shall be considered "Sensitive Information"); information relating to your account with a Publisher; and information concerning whether you have completed a User Form, made a purchase or completed some other action in response to an advertisement.
Individuals: Vendor List Information. RTX may obtain information about you after you provide information to a third party and you permit that party (the "Seller") to share the information, which RTX subsequently purchases, licenses or otherwise lawfully acquires. Such information may include, but is not limited to, your name, street address, zip code, telephone numbers, birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and/or online interests, and/or other information which you provided to the Seller (together, "Vendor List Information"). When acquiring Vendor List Information, RTX requires assurances from the Seller that the Seller has a right to transfer the Vendor List Information to RTX and that RTX may lawfully use the Vendor List Information to transmit offers from Advertisers.
(b) Web beacons. A web beacon is a programming code used to display an image on a web page and can also transfer an individual's user identification to a database and associate the individual with previously acquired information about the individual. Web beacons enable RTX to track certain websites you visit or advertisements you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at http://www.webopedia.com/TERM/W/Web_beacon.html.
(c) Where Technology Information is Collected. Technology Information is collected directly from the Site and RTX-delivered advertisements or indirectly through Publishers with whom RTX contracts to display advertisements.
(d) Advertisement Codes. To make certain that our advertisements served to Web Properties by RTX are targeted correctly, Publishers must place RTX-provided tags or tracking codes, known as advertisement codes, on or in connection with their Web Properties. The Advertisement Codes do not collect personal information, except as otherwise defined by applicable law. They are used to match Individual browsing behavior to a segment profile designated for targeting Ads to Individuals on or using the applicable Publisher Web Property.
Individuals: Email Databases. RTX may track your interaction with email advertisements sent to you by RTX or others (for example, when you register, purchase, or browse in response to such emails).
Outside Information. RTX may lawfully receive information about you from third parties, such as information located in public databases.
No Information Collected from Children Under 13. Please be advised that we do not knowingly collect personal information from children under age 13. If we become aware that a child under age 13 has provided us with personal information, we will delete it from our database. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us at email@example.com.
How We Use Your Information: Publishers and Advertisers
We use your personal information primarily for administrative purposes pertaining to your account and customer management purposes, including (a) processing payments owed to you; (b) providing reports, customer service, newsletters, RSS feeds and other information, products and/or services that you have signed up for or have otherwise agreed to receive; (c) operating the RTX Network; (d) sending you information regarding RTX and/or the RTX Network; (e) displaying content that is customized to your interests and preferences; (f) tracking with your compliance with the General Terms, and/or the RTX Platform Services Agreement, as applicable; (g) contacting you when necessary regarding your account with us and/or operational updates to our Site; and (h) for validation, suppression, content improvement and feedback purposes. Unless you indicate a preference not to receive such information when you sign up for the Site or subsequently, we may also send you surveys, marketing communications to inform you of new products or services or other information or offers that may be of interest, and/or updates about RTX. These surveys, marketing communications, or updates may come from RTX or our service providers. If you do not wish to continue to receive surveys, marketing communications or updates, you may indicate this preference by following the "unsubscribe" or "opt-out" instructions included within each email communication. Please keep in mind that, even if you choose not to receive these communications, you may continue to receive transactional or account communications (e.g., confirmation emails) and other communications which are required or permitted by applicable law.
We use Sensitive Information only to process, and provide support, servicing and fraud detection for, payments and other transactions that Publishers have requested.
You also agree that we may also use your name, company name and logo in advertising or promotional materials to refer truthfully to you as an advertising client of ours or as a Publisher in the RTX Network.
We use non-personal information primarily for internal research and analytics to improve our Site and our services.
How We Use Your Information: Individuals
We use your personal information to help us ensure that the advertisements we serve are interesting to people who see the advertisements. For example, if your privacy settings permit it, we may use your profile photo or name when serving an advertisement to a person who is your friend We use your non-personal information primarily to ensure that the advertisements we serve are targeted. For example, we may aggregate demographic data to create anonymous groups so that we can serve advertisements which may appeal to members of those groups.
Generally, RTX uses information about Individuals to target advertising and other information, such as business, weather, entertainment, sports and general news alerts and similar information, more effectively. When an Individual is online, RTX uses Technology Information to associate an Individual with their information, and RTX attempts to show information and advertising for products and services to which the person may respond. RTX may use data collected from a response to one type of advertising or information for targeting advertisements or other information through a different venue. For example, RTX may notice that you responded to a skateboarding-related advertisement and use that response to deliver a skateboarding-related advertisement and other information to you.
In addition, RTX may use Individual personal information to process transactions you have requested involving Publisher virtual currencies and to award or credit you with Publisher virtual currencies in connection with actions you have taken to respond to advertisements displayed on or in connection with Publisher Web Properties. We use Sensitive Information only to process, and provide support, servicing and fraud detection for, such transactions and activities.
Disclosure of Your Personal Information
We do not sell, rent, lease or disclose your personal information to unaffiliated entities, except in the limited circumstances listed below. (RTX may transfer information to our affiliated entities, that is, entities that control, are controlled by, or are under common control with RTX, for marketing and other purposes at our discretion.)
We may disclose your personal information to third-party service providers who perform services on our behalf. For example, we may engage other companies as data subprocessors that handle and process yoru personal information for the following purposes: to handle the processing of payments, to detect and protect against fraud, to provide data storage and management, to assist in marketing RTX's products or services, to conduct audits, to provide web analytics and business intelligence, to provide customer support, to send email and platform alerts, to provide customer surveys and messaging services, and to provide hosting, design, development and other operations which make our Site work. Other third-party service providers may help us communicate with you through electronic mail, direct mail or telephone communication. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as RTX, including not using it for any improper purpose.
We will make your personal information available to non-affiliated third parties only in the following limited circumstances:
Disclosure of Non-Personal Information
In addition to the foregoing, RTX may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons. For example, we may provide our advertisers with aggregate, anonymous non-personal informational about Individuals, including, without limitation, demographic data. This aggregate data allows us to create anonymous groups that our advertisers use to identify people who may be interested in particular products or services.
Accessing/Updating/Deleting Your Personal Information and Opting Out of Behavioral Targeting
If you would like to delete or update the personal information that we have collected from you, simply send your request via e-mail to firstname.lastname@example.org. If you are an Advertiser on the RTX platform then you may update your personal information by logging into your account at our Site and modifying your account information.Additionally, if your personal information is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, the right to object to processing of personal data, and the right to data portability. Please send an e-mail to email@example.com for more information.
We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
To prevent the display of RTX advertising on a Web Property, for example, banner advertisements, do not visit the Web Property. RTX does not respond to Do Not Track signals from web browsers. To only prevent RTX from tracking your behavior on a Web Property, turn off cookies from that Web Property and do not click on or interact with any advertisements. Facebook and other social networking platforms also provide you with the ability to change your privacy settings to limit the ability of third parties such as RTX to view your profile and other information and track your activities and content on those platforms. RTX respects your privacy settings and will not collect information in violation of those settings.
To unsubscribe from RTX or Publisher email lists, click the link included in the footer of any message delivered by RTX or a Publisher and follow the instructions provided.
Notwithstanding the foregoing, even if you unsubscribe from marketing emails, we may continue to contact you for the purpose of communicating information relating to your participation in the RTX Network, as well as to respond to any inquiry or request made by you.
If you do not request that we delete your personal information, we will retain it pursuant to our internal data retention and deletion practices as dictated by valid business and legal reasons for retaining such information. For example and without limitation, personal information relating to registered RTX Members will be retained as long as such Members have an active account or continues to communicate with us, and personal information relating to Advertisers will be retained as long as such Advertisers maintain an account with the RTX platform or as required under the applicable commercial agreements between RTX and those Advertisers.
How We Protect Your Personal Information
We know it takes confidence and trust to share personal information online. We endeavor to keep your confidence and maintain your trust by protecting your personal information. To that end, we maintain reasonable standards of security and confidentiality. For example, RTX stores Individuals' information in a database in encrypted form. In addition, RTX's computers have security measures, such as firewalls, to protect against the loss, misuse and/or alteration of the information under RTX's control. RTX also maintains physical and procedural safeguards to protect information under our control and to restrict access to those employees and agents who have a need to know in order to provide services to you and/or operate our business. We also rely as much as possible on reputable encrypted third-party payment solutions like PayPal in connection with processing payment transactions that may involve Sensitive Information.
Notwithstanding such measures, RTX cannot guarantee that its security measures will prevent these computers from being illegally accessed and the Individual information on them stolen or altered. Despite our efforts, as with most Internet sites and businesses, it is possible that third parties may unlawfully intercept or access transmissions of private communications and/or unlawfully gain access to protected computers. No method of data collection, transmission or storage is 100% secure, and we cannot warrant such absolute security. Whenever you provide personal information online, you accept this risk, including when you share your personal information with us or our Publishers or in response to an online advertisement.
Notwithstanding these inherent risks, we make a concerted good faith effort to ensure that your personal information is protected by maintaining the reasonable standards of security and confidentiality mentioned above. We require our service providers who are under contract with us to follow the same policy.
European Union Residents
If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "GDPR") and the following additional information is provided for your benefit.
The controller of the personal data collected through the Site is:
Red Spark, LP d/b/a RTX Platform, LP
160 Pine Street, Suite 320
Harrisburg, PA 17101
If you use the Site, you acknowledge that your personal data is being processed on the basis of your consent and that information gathered through the Site may be transferred to, and used and stored in, the United States.
You hereby consent to the processing of your personal data as described in this Policy, including the transfer of your personal data to, and its use and storage in, the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You may withdraw your consent at any time by following the instructions in the Accessing/Updating/Deleting Your Personal Information section below, but this will not affect the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the Site. You have the right to file a complaint relating to the processing of personal data with a supervisory authority.
Further, you consent to the use of your name in advertising or marketing materials, as further described in the "How We Use Your Information: Site Users" section above.
Privacy Practices of Third Parties
Third Party Web Technologies. Publishers and Advertisers in the RTX Network, as well as other publishers and advertisers who place advertisements on the Internet, may use their own cookies, web beacons and other Web Technologies to collect information about you. RTX has no control over third parties' use of such Web Technologies.
Links to Third Party Websites. The Site, Advertiser's advertising content, Publishers' Web Properties, and e-mail messages transmitted by RTX on its own behalf or on behalf of its Publishers or Advertisers may contain links to third-party websites ("Third Party Websites"). Please be aware that RTX is not responsible for the privacy and security practices of Third Party Websites. We encourage you to be aware when you leave the Site (or when you leave a Publisher's Web Property) and to read the privacy policies of each and every website that you visit. This Policy applies SOLELY to information collected by RTX and/or the Site.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of a breach of RTX's information security with respect to your personal information protected by those laws. Where permitted by applicable law, you will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and/or to engage in remedial measures.
Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in the rest of this Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used herein.
Categories of Personal Information:
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked directly with a particular consumer or device ("personal information"). Specifically, RTX's website has collected the following categories of personal information from its users within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Y|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Y|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||N|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Y|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||N|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Y|
|G. Geolocation data.||Physical location or movements.||Y|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||N|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||N|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||N|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Y|
For the purposes of the CCPA, personal information does not include the following categories:
Sources of Personal Information:
Submitted by You: We may collect personal information from you through your direct submission of such personal information to us through a form on a website, or through email or other direct communication from you to us.
Indirectly: We may also collect personal information about you through, including certain online activities through Web Technologies as described elsewhere in the Policy.
Third Parties: We may also collect personal information about you from third-party business partners.
Purpose for Collecting Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
RTX will not collect additional categories of personal information, or use such personal information in any way besides the uses described above without providing notice.
Sharing Your Information
Please see the "Disclosure of Your Personal Information" section above.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
Sale of Information
In the preceding twelve (12) months (as of the most recent update to this Policy), we have not sold personal information. However, we respect and understand that you may still want to ensure that your personal information is not sold. Therefore, if you would like to proceed with a "Do Not Sell My Personal Information" request, and opt-out of any future collection of your personal information, please complete the form here Do Not Sell My Personal Information.
Your Rights and Choices under the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that RTX disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
Deletion Request Rights
You have the right to request that RTX delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Red Spark, LP d/b/a RTX Platform, LP
c/o Legal Department
3675 Market Street, Suite 900
Philadelphia, PA 19104
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we reserve the right to offer you certain financial incentives, only as permitted by the CCPA, that can result in different prices, rates, or quality levels. Any such financial incentive will reasonably relate to the value of your personal information and contain written terms that outline the material aspects of the program. Any participation in such a program requires your prior opt in consent, which may be revoked by you at any time.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
If you have any questions regarding this Policy, or would like more information on our privacy practices, please contact us at email@example.com.