Privacy Policy

Effective Date: November 5, 2024

This Privacy Policy describes how RDK Management (“we” or “RDK”) collects, uses, shares and protects information that identifies you when you interact with our products, services, websites, and mobile applications (our “Services”).

This Privacy Policy does not apply to the other products, services, websites, and applications that state that they are offered under a different privacy policy. Please review the privacy policy on those websites and services directly to understand their privacy practices.

This Privacy Policy explains the following:

1. The Personal Information We Collect
2. Online User Activity, Cookies and Information Collected by Other Automated Means
3. How We Use Your Personal Information
4. How We Share Your Personal Information
5. How We Protect and Store Your Personal Information
6. Retention of your personal information
7. Your Privacy Options
8. Children’s Information
9. Updates to this Privacy Policy
10. Residents of the EEA, Switzerland, or UK
11. How to Contact Us

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1. The Personal Information We Collect

Depending on the nature of your interaction with RDK, we may collect personal information as follows:

Directly from you, when you interact with our customer service, or interact with us on behalf of your business:

• Contact Information including registration and subscription information, such as a username and password, your name, mailing address, e-mail address, phone number, employment information, and settings and subscription preferences.
• Billing Information including payment information and payment history if you engage in transactions through the Services.
• Any additional information you choose to provide us, including questions and feedback.

Automatically from you, when you interact with our Services;

• Service Activity Information including information associated with your use of your Services, such as device information and online user activity when you utilize our technology platforms, as described in the next section.

2. Online User Activity, Cookies and Information Collected by Other Automated Means

When you interact with the Services, certain information about your use of our Services is automatically collected. This includes:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number);
• Location information where you choose to provide the website with access to information about your device’s location including IP address;
• Site usage and session information. We collect information about your interaction with the Services, including the resources that you access, pages viewed, how much time you spent on a page, and how you reached our website. We also log the details of your visits to our website and information generated in the course of using our website, such as mouse movements, clicks, page visits, text entered, how long you spent on a page, and other details of your actions on our website.

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Much of this information is collected through cookies, web beacons, and other tracking technologies, which may be operated by our partners who assist us in collect information about usage of the Services, serving ads, or providing other services to you. For example, we use Google Analytics to collect usage details. You can learn more about privacy and Google Analytics by visiting https://support.google.com/analytics/answer/6004245, and opt out of collection of your data by using the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. We may also use cookies set by other third-party services.

You may be able to opt out tracking by cookies or control how information collected by cookies is used via a number of means, as described below. Your browser or device may include “Do Not Track” functionality; please note that we do not respond to such signals.

3. How We use Your Personal Information

We use the personal information we collect from you for the following purposes:

• Provide our Services to you, including managing any purchases or transactions related to the products and services you have purchased.
• Interact with you, including contacting you, responding to your requests, providing customer support, providing information about additional products, services, and promotions that may be of interest to you, and informing you about important changes to this Privacy Policy, our Terms or other policies.
• Tailor the content we display to you in our Services and communications, including advertising.
• Manage, operate, and improve the Services and grow our business, including monitoring the performance of our Services, understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, and publications, developing new products and services, and diagnosing or fixing technology problems.
• Comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of RDK, you, or others.

We may use and share information in an aggregated or de-identified manner data at our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.

4. How We Share Your Personal Information

• Service Providers and vendors. We may share your information with service providers and vendors that we believe need the information to perform a technology, business, or other professional function for us such as billing and collection, IT services, maintenance and hosting of our Services, payment processors, marketing partners, accounting, auditing, and tax services, and other professional services.
• Analytics Partners. We partner with analytics providers, who collect information via tracking technologies on our websites to assist us with measuring visits and traffic on our websites so we can measure and improve the performance of the sites.
• Advertising Partners. We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services. These third parties may use tracking technologies to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. Third parties may allow other companies to access information about you so that they may market other products you may be interested in.
• Social Media Platforms. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. To control this sharing of information, please review the privacy policy of the relevant social media platform.
• We share information with other entities in our corporate family, for purposes consistent with this Privacy Policy.
• Corporate Event. We reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
• Legal. We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

5. How We Protect and Store Your Personal Information

We take reasonable steps to protect against unauthorized access, use, or disclosure of any personal information we collect and maintain. These security practices include technical, administrative, and physical safeguards, which may vary, depending on the type and sensitivity of the information. Although we take the responsibility of safeguarding your personal information seriously, no security measures are 100% effective and we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information.

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States.

6. Retention of Your Personal Information

We keep your personal information for different lengths of time depending on the type of information and the business and legal requirements. For example, if you are a subscriber, we keep information that personally identifies you as long as you subscribe to one or more of our Services. If you no longer subscribe to a Service, we still may need that information for business and legal requirements, such as to protect against fraud, calculate taxes, or respond to legal requests. Other information is deleted automatically after a set period of time, often set by law, unless we are legally required to hold it longer, such as for pending litigation. We destroy, de-identify, or anonymize the information when it is no longer needed in identifiable form.

7. Your Privacy Options

You may have certain choices when it comes to how we collect and use your Personal Information:

• Email Marketing. You can opt out of receiving RDK-related promotional e-mail from RDK Management using the opt-out link found in the footer of any of these e-mails. You can also e-mail the request to the attention of “RDK Management – E-mail Opt Out” via e-mail to info@rdkcentral.com.
• Online Activity Tracking and Interest-Based Advertising. You can also modify your browser setting to disable or reject cookies across the internet; but if you do so, some features of our website or Services may not function properly or be available. If you are visiting the Services from a mobile device, the operating system of the device may offer you options regarding how the device collects and uses your information for interest-based advertising. Please visit https://thenai.org/opt-out/mobile-opt-out/ for more information. You may be able to prevent third parties from using your information for interest-based advertisements across the internet by visiting http://www.networkadvertising.org or http://www.aboutads.info. Please note this does not opt you out of being served ads, nor will it prevent the receipt of interest- based advertising from other companies that do not participate in these programs.

8. Children’s Information

This website is not directed to children under the age of 13, and RDK Management does not knowingly collect personal information from anyone under the age of 18 on this website. If we have inadvertently collected the personal information of a minor, or equivalent minimum age depending on jurisdiction, a parent or guardian of that child may contact us at  info@rdkcentral.com to request that we delete the information from our records or otherwise cease the use of that information.

9. Updates to This Privacy Policy

We may make changes to this Policy from time to time. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. We may also notify you in other ways from time to time about the collection, use, and disclosure of your personal information described in this Policy.

10. Individuals in the EEA, Switzerland or the UK

The EU General Data Protection Regulation and the UK General Data Protection Regulation provide individuals located in the EEA, United Kingdom, and Switzerland the rights to receive notice regarding the purposes for which your data are processed and the legal basis for our processing, the categories of recipients of your personal information, whether the personal information will be transferred outside these jurisdictions, and the criteria we use to determine how long to retain your data. You also have the right to receive notice about your rights. These rights apply to all individuals in these locations, regardless of whether you are a customer, business contact, or member of the workforce.

The GDPR defines “Personal Data” to mean “any information that is linked or reasonably linkable to an identified or identifiable natural person.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.

Right to be Informed

The general section of this Privacy Policy describes the types of personal information we collect, how we collect it, and how we use it in categories that are easy to understand. For information on our retention practices, please see How long we keep your information above.

Legal Basis For Processing

We rely on a variety of legal bases to process your personal information. We mainly process your personal information because it is necessary to perform our agreement to provide the Services to you or because the processing is necessary for our legitimate interests where those interests do not override your fundamental rights and freedoms related to data privacy. Where we rely on legitimate interest as this lawful basis, our legitimate interest is necessary for promoting our business, improving the services we offer to you and your experience when you interact with us, and ensuring effective operational management and internal administration of our business and the exercise of our rights. In limited circumstances, we may rely on other legal bases for processing your personal information, including when necessary to comply with a legal obligation or where you provide your consent for processing.  Certain personal information may be transferred to and processed in the US and other countries where we have facilities or in which we engage service providers. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Cross-border Transfer of Information

Certain personal information may be transferred to and processed in the US and other countries where we have facilities or in which we engage service providers. The laws in the U.S. regarding personal information may be different from the laws of your state or country. We implement appropriate safeguards to protect your personal information as required by relevant law, including supplemental measures, if we transfer your personal information outside of the EEA, UK, or Switzerland.

Right of access, right to data portability, right to request correction, and right to request deletion of information

You have the right to request that we:

• Give you access to, and a copy of your personal information we hold in our systems;
• Correct or update inaccurate or incomplete personal information we have about you;
• Delete all or some of the personal information we have about you (e.g., if it is no longer needed to provide Services to you)

To submit a request to exercise your rights, please email info@rdkcentral.com. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response. Please note that, in order to verify your identity, we may require you to provide us with information prior to accessing any records containing information about you. In certain circumstances, we may not collect sufficient identifiers to match information in our records with your request.

Right to object, withdraw consent, and restrict processing

You have the right to request that we:

• Stop using, and ensure that all third parties stop using, some or all of your personal information (e.g., if we no longer have a legal basis to process it);
• Stop contacting you with promotional messages.

To submit a request, please email info@rdkcentral.com.

Right to opt out of automated processing

You have the right to opt-out of automated processing where such processing would produce legal or other similarly significant effects. However, we do not use personal information of residents of the EEA, Switzerland, and United Kingdom to make automated decisions about you that would have these effects.

Lodging a Complaint

You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available at https://ec.europa.eu/newsroom/article29/items/612080.

11. How to Contact Us

If you have questions about this Privacy Policy, send us a message: info@rdkcentral.com.

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