• • 2.1 GENERAL

The following sections cover the specifics of the three groups from which data is collected: website Visitors, Consumers, and Users.

• • 2.2 WEBSITE VISITORS

If you are a Visitor to our website only, and not a Consumer who has called a phone number controlled by RDX or a user of our platform, then this section is relevant for you.

By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.

RDX may collect, record and analyze information of Visitors to its website. We may record your IP address and use cookies. RDX may add information collected by way of pageview activity. Furthermore, RDX may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you request a demo or sign up for information and newsletters. If you provide RDX with your social media details, RDX may retrieve publicly available information about you from social media.

Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in RDX products, and certain information about the company you are working for (company name and address), the referring site that lead you to our page or a page with RDX’s JavaScript placed on it, user agent string, browser type and version, device type, operating system type and version, as well as information as to the type of relationship that exists between RDX and yourself. RDX may also use your IP address to extrapolate your approximate geographic location, internet service provider, and other location based data.

RDX gathers data about visits to the website, including numbers of Visitors and visits, length of time spent on the site, pages clicked on or where Visitors have come from.

• • • 2.2.1 PURPOSE OF PROCESSING PERSONAL DATA

  RDX uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website and 3rd party websites that use the RDX JavaScript by analyzing how Visitors navigate its website.

• • • 2.2.2 SHARING PERSONAL DATA

  RDX may also share such information with service vendors, clients, or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.

• • • 2.2.3 COOKIES

  Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread and benefits the surfer.

• • • 2.2.4 LINKS TO OTHER SITES

  Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. RDX is not responsible for the content or privacy policy of these other sites.

• • 2.3 CONSUMERS

Consumers should be aware that in calling phone numbers issued by RDX, they could be disclosing information that could make them personally identifiable to RDX Users. The security and privacy protection implemented on RDX’s platform does not cover this type of transfer or disclosure of personal information. Consumers calling a phone number that may be issued by RDX and licensed to a RDX User should be aware that they are making themselves personally identifiable by their phone number’s ‘Caller ID’ and that they are solely responsible for their actions while on the phone with whatever party they requested to speak with. For more detailed information concerning the protection of privacy when calling a RDX issued phone number may contact the entity they requested to speak with. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law.

• • • 2.3.1 INQUIRIES

  If you wish to inquire about your Personal Data that may have been collected in a phone call through RDX, we recommend that you contact the entity that you called and spoke with. As RDX is a Processor in this regard, it does not control the Personal Data used or stored from the call, but processes it on behalf of its User.

• • 2.4 USERS

If you are a User of our platform only, and not just a Visitor then this section is relevant for you.

• • • 2.4.1 GENERAL

  In order to provide services to its Users, RDX collects certain types of data from them. Furthermore, RDX’s Users collect information from Consumers when call a number issued to a RDX User. This section will describe how these two types of data are collected and used by RDX as well as geographical differences that effect this policy. Data entered or transferred into RDX by Users such as campaign names, target names, publisher names, sub-account information, etc., remains the property of the User and may not be shared with a third party by RDX without express consent from the User.

• • • 2.4.2 COLLECTION OF USER DATA

  During a User’s registration and later on RDX’s platform, they provide information such as name, company name, email, address, telephone, credit-card number and other relevant data. This information is used by RDX to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.

  RDX Users can at any time access and edit, update or delete their contact details by logging in with their username and password to RDX’s platform. RDX Users may create more Users with different privilege levels within their account. It is the responsibility of the User that creates other User accounts, to choose the level of access each User should have. Once these new Users log into RDX, they meet the definition of User in this policy. RDX will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

• • • 2.4.3 COLLECTION OF CONSUMER DATA

  Users may issued phone numbers to be used on their behalf or by making them available to relevant businesses, organizations, and individuals. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. RDX will not process Personal Data for other purposes or by other means than instructed by its Users.

  Consumer data includes data from individuals who called a phone number issued by RDX, ‘Caller ID’ numbers from Consumers who may have called, and meta-data collected by RDX JavaScript in some cases. Personal Data may include, personal contact information such as IP address, geographic location information such as country, region, city, state, postal code, latitude, and longitude, internet service provider data, referring URLs, browser header data, user-agent strings, device type, browser type, operating system type, phone provider carrier data and other sensitive Personal Data. Consumers may also disclose personal data inside of a call recording, should a User instruct RDX to record a call. Call recordings are the property of RDX Users and should you have questions about the contents of a call recording, please contact the party in which you called.

  The purpose of collecting Personal Data as part of a phone call will vary depending on the User, as set up by RDX’s Users. As RDX provides phone numbers to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA, or for Users issued phone numbers in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by RDX’s User.

  If you or your organization are required under the European Union’s General Data Protection Regulation (GDPR) to enter into a contract, or other binding legal act under EU or Member State law, with your data processors, review and accept RDX’s Data Processing Agreement in your RDX account.

• • • 2.4.4 GEOGRAPHICAL LOCATION

  RDX offers a number of data regions. A RDX “Data Region” is a set of data centers located within a defined geographical area where User and Consumer data is stored, maintained by RDX or a 3rd party service provider that acts as RDX’s data processor. Personal Data is not transmitted between Data Regions. For RDX Users with accounts located in RDX’s European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in the respective country. For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.

• • • • 2.4.4.1 PROCESSING IN THE EUROPEAN ECONOMIC AREA (EEA)

    For Users with accounts located in RDX’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and RDX’s processing will take place in accordance with the GDPR.

• • • • • 2.4.4.1.1 CONTROLLER

      RDX processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
      The RDX entity which you as a User entered an agreement with when using RDX’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section.

      For Consumer data, as outlined in the “Collection of Consumer Data” section, the User will be the Controller in accordance with Directive and GDPR, and RDX will be the Processor.

      RDX adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, RDX processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only.

      All data collected by RDX Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services. RDX has a data processing agreement in place with its providers, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

• • • • 2.4.4.2 PROCESSING IN NORTH AMERICA

    For Users with accounts in the RDX North America Data Region, RDX processes data solely in data centers located in the US. RDX has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in RDX’s possession. RDX will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

    All data collected by RDX Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, or Twilio. RDX’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. RDX’s policy is to protect and safeguard any personal information obtained by RDX in accordance with United States state or federal laws governing the protection of personal information and data. Accordingly, RDX adheres to practices and policies that aim to safeguard the data.

• • • • 2.4.4.3 PROCESSING IN OTHER REGIONS

    For Users with accounts in our Asian Pacific Data Region, RDX processes data in data centers throughout Asia, and in the US. RDX has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in RDX’s possession. RDX will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

    All data collected by RDX Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, or Twilio. RDX’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. Accordingly, RDX adheres to practices and policies that aim to safeguard the data.
    All data collected by RDX Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, or Twilio. RDX’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. Accordingly, RDX adheres to practices and policies that aim to safeguard the data.