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:
|A. Individual Identifiers and Demographic Information||Name, postal address, email address, and telephone number, or other unique identifiers.|
|B. Commercial Information||Payment card information, payment preferences, order details, reservations, booking and special request information, or other purchasing or consuming histories or tendencies.|
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:
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:
3. SHARING OF PERSONAL INFORMATION
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.
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.
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: firstname.lastname@example.org. 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.
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.
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.
|Processing Purpose||Lawful Basis|
|Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Redeam Platform.|
|Processing is necessary for the performance of a contract. You are subject to a contract with us and we need to use your personal information to provide products and services.|
|Processing is necessary to comply with our legal obligations.|
|Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).|
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:
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:
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.
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.
|Category||Personal Information is Disclosed for a Business Purpose||Personal Information is Disclosed for Valuable Consideration|
|A. Individual Identifiers and Demographic Information||Yes||No|
|B. Commercial Information||Yes||No|
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.
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).
11.1 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
1401 Walnut St, Ste 200
Boulder, CO 80302
Date of last update: April 7, 2020