United States Supplemental Privacy Notice

Last Revised: 10/19/2023

RedVMX maintains a global privacy program as described in our Global Privacy Notice. This US Privacy Notice supplements our Global Privacy Notice by providing additional disclosures required by US state law. For disclosures specific to your state, please click the relevant link below:

If your state is not listed above, please see our Global Privacy Notice for a description of your rights.

 

Additional California Disclosures

Our Global Privacy Notice applies to all California residents.

The following additional California-specific disclosures are required by California law and relate to both our online and offline practices for handling “Personal Information” (as defined below) of California residents.

The California Consumer Privacy Act (CCPA) regulates the processing of Personal Information, which is defined as “information that identifies, relates to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household.” For purposes of honoring rights of California residents, all references to PII in our Global Privacy Notice include personal information as defined in the CCPA.

 

Categories of Personal Information Collected

In the last 12 months, we have collected the following categories of personal information for the business purposes described below.

CategoryExamplesBusiness Purpose
IdentifiersName, postal address, telephone number, email address, IP address, driver’s license number, passport number, or other similar identifiersManaging accounts, processing purchase requests, security, detecting fraud, marketing, advertising, and employment
Personal Information Categories listed in California Consumer Records StatuteName, postal address, telephone number, financial information (e.g., account number or card number), employment informationManaging accounts, processing purchase requests, security, detecting fraud, marketing, advertising, and employment
Commercial InformationServices purchased and other information about our customers’ enterprisesManaging accounts, processing purchase requests, security, detecting fraud, marketing, and advertising
Internet or other similar network activityInformation about the use of our website and services, interaction with advertising, IP address, and similar informationManaging accounts, processing purchase requests, security, detecting fraud, marketing and advertising
Professional or employment related informationInformation about our employees, job applicants, and our customers’ employer(s), position, and job responsibilitiesManaging accounts and employment
Inferences drawn from other personal informationInferences regarding our customers’ businesses and interestsMarketing, advertising, and customer support
Audio, electronic, visual, thermal, olfactory, or similar informationRecordings of customer support calls, voice messages, SMS and text messages, and security videoManaging accounts, customer support, and security
Biometric informationAccess to company computer systems and facilitiesSecurity

Categories of Sensitive Personal Information Collected

Users of some services are required by applicable laws, contracts, and other requirements to supply certain information that is defined as “Sensitive Personal Information” under California law.

In the past 12 months, we have collected the following categories of Sensitive Personal Information from some individuals:

  • Identifiers: Social security numbers, driver’s license numbers, state identification card numbers, or passport numbers
  • Personal Information Categories listed in California Consumer Records Statute: account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to an account

Categories of Personal Information Disclosed

In the past 12 months, we have disclosed the following categories of Personal Information for the business purposes described above (see, Categories of Personal Information Collected) to the following categories of third parties:

CategoryExamples
Identifiers
  • Service providers
  • Business partners
Personal Information Categories listed in California Consumer Records Statute
  • Service providers
  • Business partners
Protected classification characteristics under California or federal law
  • Service providers
  • Business partners
Commercial Information
  • Service providers
  • Business partners
Internet or other similar network activity
  • Service providers
  • Business partners
Professional or employment related information
  • Service providers
Inferences drawn from other personal information
  • Service providers
  • Business Partners
Audio, electronic, visual, thermal, olfactory, or similar information
  • Service providers
Biometric information
  • Service providers
Education information
  • Service providers

No Sale of Personal Information

We do not sell Personal Information.

 

Sharing of Personal Information

The CCPA defines “sharing” personal information to include providing personal information to third parties for certain online behavioral advertising purposes. Pursuant to this CCPA definition, we “shared” personal information with third parties for customized and personalized marketing and advertising in the past 12 months, including identifiers, internet or other similar network activity, and inferences drawn from other personal information. The recipients of this personal information are prohibited from using this shared personal information except to provide services to us or as otherwise required by law.

We recognize the right for California residents (and all other individuals regardless of where they live) to opt-out of the “sharing” of personal information by clicking on the Do Not Share My Personal Information link in this notice and on our website. You can also request that we not share your personal information by emailing us at [email protected].

 

Use of Sensitive Personal Information

RedVMX does not use sensitive personal information, as defined in the CCPA, for any purpose other than:

  • providing the services or goods requested by our customers
  • preventing, detecting, and investigating security incidents
  • detecting and responding to malicious, deceptive, fraudulent, or illegal actions
  • to ensure the physical safety of natural persons
  • for short term, transient use, including but not limited to, nonpersonalized advertising shown as part of a consumer’s interaction with us
  • to service accounts
  • to verify or maintain the quality or safety of products, services, and/or devices that are owned, manufactured, manufactured for, or controlled by us
  • for employment purposes

As a result, the right to limit use of sensitive personal information under the CCPA does not apply to our activities.

 

How to Exercise Your Rights

You can make a request to exercise your rights to know, access, correct, delete, transfer (portability), opt-out of marketing, or restrict sharing of your personal information by emailing us at [email protected]. You also can send your request by mail to:

RedVMX
Attn: Legal – Privacy
44927 George Washington Blvd STE #265
Ashburn, VA 20147 USA.

If we require additional information to process your request, we will contact you by email or mail.

 

Use of Authorized Agents

The CCPA allows authorized agents to make requests on behalf of California residents to exercise their personal information rights. To exercise rights on behalf of a California resident, authorized agents must provide us with evidence they are authorized to make the request.

To make an authorized request, please email us at [email protected]. Authorized agents can also send their requests to RedVMX Attn: Legal – Privacy, 44927 George Washington Blvd STE 265, Ashburn, VA 20147 USA.

Please note that we will confirm the authorized agent’s authority and send any personal information directly to the California resident on whose behalf the agent is acting. No personal information will be provided to the authorized agent.

Time To Respond

We will acknowledge your request to exercise your rights within 10 business days after receiving the request. Under California law, we have 45 days to respond to your inquiry and may add an additional 45 days depending on the complexity of your request. Please note, however, that as a general rule we normally respond to requests within 30 days as set forth in our global privacy notice.

 

Supplemental Colorado, Connecticut, and Virginia Disclosures

 

Our Global Privacy Notice applies to all Colorado, Connecticut, and Virginia residents. The following supplemental disclosures are specifically required by state law.

Colorado, Connecticut, and Virginia regulate the processing of “Personal Data”, which generally has the same definition as PII in our global privacy notice. We recognize all requests to exercise state privacy rights as including both personal data under applicable state law and PII as defined in our global privacy notice.

 

Mandatory Disclosures

  • We process the following categories of personal data: identifiers/contact information, demographic information (including gender and age), payment card information, commercial information (such as information about your business), internet activity, audio and electronic information, and inferences.
  • The purposes for processing your personal data are described in our global privacy notice.
  • We may disclose all of the categories of personal data described above to the third parties described in our global privacy notice.
  • We process the following categories of personal data for targeted advertising purposes: identifiers, demographic information, commercial information, internet activity, and inferences.

The Right to Opt-Out of Marketing and Advertising

We recognize the right to opt-out of targeted marketing and advertising communications. You can exercise this right by sending us an email at [email protected]. If you are a customer, you can also opt-out of targeted marketing and advertising communications by setting your advertising and marketing preferences in your account. You also can send your request by mail to: RedVMX Attn: Legal – Privacy, 44927 George Washington Blvd STE 265, Ashburn, VA 20147 USA.

We also recognize the right to opt-out of the processing of personal data for targeted advertising through a third party authorized by you to act on your behalf. We reserve the right to use commercially reasonable methods to authenticate your identity and the authorized agent’s authority to act your behalf. Authorized agents may make such requests by sending us an email, or mailing the request to RedVMX Attn: Legal – Privacy, 44927 George Washington Blvd STE 265, Ashburn, VA 20147 USA.

 

How to Exercise Your Rights

You, or an authorized agent, may make a request to exercise your rights to know, access, correct, delete, transfer (portability), or opt-out of marketing by emailing us at [email protected]. You, or an authorized agent, can also send your request by mail to:

RedVMX
Attn: Legal – Privacy
44927 George Washington Blvd STE 265, Ashburn, VA 20147 USA.

We reserve the right to use commercially reasonable methods to verify your identity and the authority of any authorized agent to act on your behalf.

Time To Respond

Under state law, we have 45 days to respond to your inquiry and may add an additional 45 days depending on the complexity of your request. Please note, however, that as a general rule we normally respond to requests within 30 days as set forth in our Global Privacy Notice.

 

Right of Appeal

If we reject your request, you have the right to appeal that denial by notifying us that you disagree with our decision by email at [email protected] or by mail at: RedVMX Attn: Legal – Privacy, 44927 George Washington Blvd STE 265, Ashburn, VA 20147 USA.

If you choose to appeal, please explain why you believe you are entitled to receive the information requested despite our denial. We will respond to any appeal within 45 days.

Right to Complain to Attorney General

If we deny any request you made under our Global Privacy Notice or this state supplemental notice, you may file a complaint with your state’s attorney general.