PRIVACY POLICY

Redeam (“Redeam”, “we”, “our”, “us”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) our online and offline practices regarding the personal information that Redeam collects, uses, and shares on behalf of end users (“Users”) of our online      software, including bookings, inventory management and, customer relationship software (the “Redeam Platform”) accessed through the website located at www.redeam.com, and any other websites or application operated by Redeam (each, a “Website”) or provided to Redeam through an integration, including an Application Programming Interface (API), with a Supplier’s or reseller’s platform (each, an “Integration”) (each Website and Integration treated as a part of the “Redeam Platform” for purposes of this Privacy Policy). We operate and are responsible for the Redeam Platform, which helps you purchase products and services such as tours, attractions, and activities (the “Services”) that deliver the admission tickets related to products or services (the “Tickets”) of our associated attraction, tour, or activity operators (each, a “Supplier”). Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Redeam Terms & Conditions posted on the Website.

In some cases, we may act as a processor or service provider of Supplier with which you have a customer relationship. In such a situation, the Supplier has engaged Redeam to provide Services. This Privacy Policy does not apply to the non-personal information described below that is collected by, used by, disclosed by, or disclosed to the Supplier. This Privacy Policy only applies to Redeam’s collection, use, and disclosure of personal information. For more information about the Supplier’s privacy practices please contact the Supplier directly.

Redeam reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Redeam Platform following posting of changes constitutes your acceptance of such changes.

1. COLLECTION OF PERSONAL INFORMATION

1.1 Personal Information. The following are categories (with non-exhaustive examples) of personal information we may collect about you and for each category the purpose for which it may be used:

1.2 Sources of Personal Information. We obtain the categories of personal information listed above on or through our Redeam Platform from the following categories of sources:

• Personal Information You Provide. Redeam collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from Users when a User signs up to receive promotional communications; uses or accesses a Service or content available through the Redeam Platform; participates in one of our promotional sweepstakes, contests, or surveys; posts a review; submits a request to our customer service team; interacts with our social media pages; or otherwise interact with us through the Redeam Platform.
• Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly, Redeam may receive personal information about you from other third party sources. For example, we receive personal information from Suppliers, business partners, or companies that provide personal information to supplement what we already know about Users. We may merge or combine such personal information with the personal information we collect from you directly.

2. USE OF PERSONAL INFORMATION

Redeam’s primary purpose in collecting personal information is to provide the Services that you request on the Redeam Platform. Redeam may also use personal information for various purposes, including without limitation to:

• To Provide Products and Services. This could include fulfilling your requests for Tickets to our Supplier’s products or services. This may include the release of your personal information to the parties to the transactions with you for the purpose of giving effect to those transactions. For example, we are authorized to release the personal information required for the issuance of Tickets or similar booking reservations, and we may release to agents or resellers the personal information of Ticket or voucher holders required to process the payment and track admission. If you provide your personal information to purchase a product or service, we will use such information to process your payment and facilitate delivery. We may also save your personal information to facilitate new product or service orders, or process returns.
• To Improve the Redeam Platform or Services. We use personal information to understand and analyze the usage trends and preferences of our Users to make our Redeam Platform or Services better, diagnose technical issues, prevent fraud, and develop new features and functionality.
• To Understand Your Interests. We may use your personal information to personalize your experience on the Redeam Platform and to deliver information about products and services relevant to your interests.
• To Process Your Payment for Products and Services. We use personal information to facilitate payment for products and services that you select through our Redeam Platform.
• To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
• To Market Products or Services. We provide you with information about products, services, or promotions. These might be offers from our Suppliers that we think you might find interesting.
• To Secure the Redeam Platform. We use personal information to maintain the safety, security, and integrity of our Redeam Platform, databases and other technology assets, business, and other Users.
• To Communicate with You. We may communicate with you about your transactions or our relationship. We may also contact you about this Privacy Policy or the Terms & Conditions.
• As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

3. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, Redeam may share your personal information in the following circumstances:

3.1 Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Redeam Platform. Among other things service providers may help us perform website hosting, application design, maintenance services, database management, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other uses set out in this Privacy Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal information that they are provided with confidential and to comply with all applicable laws.

3.2 Supplier Offerings. We may jointly offer events, promotions, or any other product or service offerings with Suppliers. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the personal information we maintain about you. Suppliers may collect      information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a Supplier, the information that you provide may be shared with us and with that identified Supplier.

3.3 Referrals. Users may recommend other Users to join the Redeam Platform by providing their contact information. Users may also provide information about other Users of the Redeam Platform such as reviews of the services or products that he or she received, booking or scheduling information, or reference information.

3.4 Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.

3.5 Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms & Conditions.

3.6 Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.

4. SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

5. YOUR CHOICES

You can make the following choices regarding your personal information:

5.1 Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.

5.2 Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us      as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law. 

6. OPTING OUT

You can make the following choices to opt out of certain activities regarding your personal information:

6.1 Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Redeam Platform, as well as offers from Suppliers. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you Service-related communications, such as those about your Tickets, to fulfill Orders for products and services you have requested, or deliver notifications directly to you through the Redeam Platform.

6.2 Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Redeam is based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms & Conditions related to the use of and access to the Redeam Platform.

7.1 Transfer Mechanism. Redeam participates in the EU-U.S. Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries. We have certified with the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, click here. If you have any inquiries or complaints about our handling of your personal information under Privacy Shield, or about our privacy practices generally, please contact us at: privacy@redeam.com. We will respond to your inquiry promptly. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions. As explained here, we sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal information must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. Redeam is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

7.2 Dispute Resolution. In compliance with the Privacy Shield Principles, Redeam commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about our use of personal information or our Privacy Policy should submit a written request to us using the contact information below.

Redeam has further committed to cooperate with JAMS, Redeam’s Privacy Shield Dispute Resolution provider with regard to unresolved Privacy Shield complaints concerning personal information transferred from the EU. If you are unable to satisfactorily resolve your complaint directly, you may open a case with JAMS.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

We self-assess our practices to assure compliance with this Privacy Policy and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Privacy Shield Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Privacy Shield Principles.

8. RESIDENTS OF THE EUROPEAN ECONOMIC AREA

The following applies to individuals in the European Economic Area (EEA).

8.1 Lawful basis for processing. Redeam is required to inform you of the lawful basis of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “CONTACTING US” below.

We will use your personal information only for the purposes for which we collected it, which may include where we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of personal information to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such information reduces the likelihood of improper disclosure of that information. To the extent necessary for those purposes, we take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.

PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

8.2 Retention. Redeam retains your personal information:

• For so long as needed to provide you with the Redeam Platform or to fulfill our contractual obligations.
• As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
• For so long as is necessary for the purposes for which we collected such personal information.

8.3 Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Correct. Update or correct inaccuracies in your personal information.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
• Delete. Delete your personal information.

When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

If you are a resident of the EEA and would like to exercise any of these rights, please submit your request to the address listed in the section titled “CONTACTING US” below. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction. You can find your data protection regulator here.

9. RESIDENTS OF CALIFORNIA

The following applies to residents of California.

9.1 Notice to California Residents. Redeam must disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the preceding twelve months, we have disclosed the following categories of Personal Information in the manner described.

9.2 Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Redeam are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “CONTACTING US” below.

 CHILDREN’S PRIVACY

Redeam takes children’s privacy seriously. Redeam asks children under the age of 13 not to send any personally identifiable information through Redeam’s website without the consent of their parents or guardians. Redeam encourages all parents and guardians to instruct their children in the safe and responsible use of personal information on the internet. Redeam will not knowingly collect, use, or disclose to third parties any personal information collected from children, and we are committed to complying with applicable laws and requirements, such as the United States’ Children’s Online Privacy Protection Act (COPPA).

11. EXERCISING YOUR PRIVACY RIGHTS

When exercising the rights or options described in this Privacy Policy, the following guidelines apply:

11.1 No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

 11.2 What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

11.3 Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

11.4 No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.

11.5 Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide the requester’s identification information and the authorized agent’s identification information.

12. CONTACTING US

Questions, comments, or complaints regarding our Privacy Policy or data collection and processing practices can be mailed or emailed to:

Redeam, Inc
PO Box 7295
Broomfield, CO 80021
E-Mail: privacy@redeam.com

Date of last update:  February 3, 2021