We value your privacy and want to be accountable and fair to you as well as transparent with you with regard to our processing of your personal data. We are RedFenix INC, (“RedFenix”, “we” or “us”), and we are the data controller of the personal data that we collect from you when using the Service (as defined in our Terms of Service: (https://www.redfenix.network/terminos).
When you create a user account on RedFenix, we may ask you for information such as your username, password, email address and picture. If you connect to the Service using credentials from a third party application (e.g., Facebook or Google), you authorize us to collect your authentication information, such as your username, email address and encrypted access credentials. We may also collect other information available on or through your third party application account, including, for example, profile picture, country and hometown, date of birth, gender and networks.
When you use the Service, certain information will be collected automatically from your online interactions, including information about your use of the Service, your IP address, location data, device ID, time, SSID (Wi-Fi network name), MAC address of access point, signal level, device location, captive portal login steps and other technology on the devices you use to access the Service.
If you have connected your user account with us to a third party application, we may receive similar information related to your interactions with the Service from such channels.
We collect, store and use your personal information including your username and email address and information about how you use and access the Service because it is necessary in order to provide the Service requested by you pursuant to the contract made between you and us. If you do not provide us with this information we will not be able to provide you with the Service.
DISCLOSURE OF PERSONAL DATA
We may share and disclose your personal data to the following parties under the following circumstances:
Third party service providers: We will share information with third party service providers to facilitate our provision of the Service or in order for such third party service provider to provide certain services on our behalf. This will include:
IT infrastructure companies that facilitate our provision of the Services to you; and other third party service providers, such as hosting providers or other IT service providers for the purpose of providing the Service or tracking your use of the Service and advertising and survey service providers to help us in our communication with you and to better understand your use of the Service. These companies are authorized to use your personal data only as necessary to provide these services to us.
Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe in our sole discretion it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified afterwards via e-mail and/or a prominent notice on our Service of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
Other users: Your user name and picture may be disclosed to other users of the Service.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
When transferring personal data outside the EU/EEA, we will ensure that the country in which your personal data will be handled has been deemed “adequate” by the EU Commission under Article 45 of the General Data Protection Regulation (“GDPR”) or if your personal data will be transferred to a country which the EU Commission does not consider to have an adequate level of protection for personal data, we will take all necessary steps required under applicable law in order for such transfer of information across borders to be compliant with applicable law. We will only transfer your personal data to a country outside the EU/EEA where; (i) the transfer is being safeguarded by the use of EU model clauses (under Article 46.2 in the GDPR) or (ii) where the recipient is certified under the US-EU Privacy Shield Framework (under Article 45 in the GDPR). RedFenix may transfer your personal data to the following countries: USA.
You can find further information about the rules on data transfers outside the EU/EEA, including the mechanisms that we rely upon, on the European Commission website (https://ec.europa.eu/info/law/law-topic/data-protection_en).
We will keep your data for as long as you have an account in the Service or for as long as we need to keep any personal data to comply with our legal obligations, resolve disputes, or enforce our agreements. After this your personal data will be deleted.
LINKS TO OTHER WEBPAGES
RedFenix take all reasonable technical and organizational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and any other unlawful forms of processing. Whilst we take appropriate technical and organizational measures to safeguard the personal data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
NOTICE OF CHANGES
You have the right to, at any time, receive a copy of the personal data that we hold about you and information about the processing.
You have the right to, without undue delay, have incorrect or irrelevant personal data about you corrected and taking into account the purposes of the processing, you have the right to have incomplete personal data about you completed.
You have the right to have your personal data deleted without undue delay and RedFenix is obliged to delete your personal data without undue delay if, for example one of the following grounds applies: the personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed, or if you withdraw consent on which the processing is based and where there is no other legal ground for the processing. Please note that we are not obliged to delete the personal data if we can show that the processing is necessary, for example, for compliance with a legal obligation to which RedFenix is subject, such as book-keeping rules or the establishment, exercise or defense of a legal claim, or when there are other legitimate grounds to keep the data.
Furthermore, you have the right to request that RedFenix restricts the processing of your personal data under certain conditions, for example if you contest the accuracy of the personal data, the processing may be restricted for a period enabling RedFenix to verify the accuracy of the personal data or if RedFenix no longer needs the personal data for the purposes of the processing but you require the personal data for the establishment, exercise or defense of legal claims.
You have the right to object, on grounds relating to your particular situation, at any time to RedFenix’s processing of your personal data if the processing is based on, for example, legitimate interests, including marketing and/or profiling based on a legitimate interest. If you object to such processing, RedFenix will no longer be entitled to process your personal data based on such legal basis, unless RedFenix can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedom or if it is conducted for the establishment, exercise or defense of a legal claim.
You have, under certain conditions, the right to receive the personal data concerning you and which you have provided to RedFenix, in a structured, commonly used and machine-readable format and have the right to transmit such personal data to another data controller without RedFenix trying to prevent this, where RedFenix’s processing of your personal data is based on your consent or on a contract and the processing is carried out by automated means. You have in such case the right to request that the personal data from RedFenix shall be transmitted directly to another data controller, where technically feasible.
You also have the right to, at any time, withdraw your consent given to RedFenix for the processing of your personal data e.g. for marketing purposes. If you withdraw your consent, please note that this does not affect the lawfulness of the processing based on your consent before its withdrawal and that RedFenix may, under certain circumstances, have another legal ground for the processing and therefore may be entitled to continue the processing.
If you are unhappy with our processing of your personal data and/or consider it to be in contrary to applicable legislation you may lodge a complaint with a competent supervisory data protection authority (“DPA”) (such as with the DPA in your country of residence, the DPA in the country of your place of work or the DPA in the country where the alleged infringement has occurred).
To exercise the aforementioned rights please contact us at the following address: firstname.lastname@example.org or RedFenix INC, 4111 NE 2nd Way Pompano Beach, FL, USA 33064-3514. In order to ensure that you receive a swift response, please state in your letter your full name and, if applicable, your address, user name and the email address used for registration. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Date of emission: 25. 10. 2018, Last Revision 04. 05. 2019
With ❤❤❤ Team RedFenix