Red-Spark.com Website Privacy Policy

Last Updated: March 9, 2020

Thank you for visiting the Red Spark website located at the http://red-spark.com domain. This privacy policy ("Policy") describes how personal information you voluntarily provide or authorize to be released, or which is publicly available or lawfully obtainable from third parties, may be obtained and used by Red Spark, LP and its operations, (collectively, "Red Spark", "we" or "our"). If you are a user of Red Spark's website located at the http://Red-Spark.com domain, or any of the materials, products or services provided on or through those websites (collectively, the "Site"), or if you are a publisher, content provider, advertiser, or other third party that utilizes the Red Spark services, you agree to this Policy, in its entirety, when you: (a) access or use the Site; (b) provide information through the "Contact Us" page of the Site; or (c) register on the Site. If you do not agree to this Policy in its entirety, you are not authorized to use the Site in any manner or form whatsoever. Additionally, this Policy is provided for informational purposes so that customers and users of Red Spark can better understand how Red Spark collects, discloses and uses personal information about them.

This Policy does NOT apply to any Company products or services, or the practices of third parties or other companies and persons that Red Spark does not own or control or to persons that Red Spark does not employ or manage. We reserve the right to change the terms of this Policy at any time. When we make changes, we will revise the "last updated" date at the top of the Policy and post the changed policy on the Site. If there are material changes to this Policy or in how Red Spark will use your personal information, we will notify you by prominently posting a notice of such changes here or on our homepage. Your provision of any information on or through the Site following such notification shall constitute your consent to the collection, disclosure and use of such information in accordance with the changed Policy. Accordingly, we encourage you to review this Policy whenever you visit the Site in order to familiarize yourself with the most recent version. Furthermore, Red Spark retains its right to offer new lines of business and, if and to the extent it does so, may display a different privacy policy to the consumer for such lines of business.

Introduction

Our Policy is intended to explain our privacy practices concerning information about you, including:

• The kinds of information we collect;
• How we use information we collect;
• Disclosure of information we collect;
• How you can access, update and delete your personal information; and
• How we protect personal information.

European Union Residents

If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (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, and repealing Directive 95/46/EC (the "GDPR") and the following additional information is provided for your benefit.

The controller of the personal data collected through the Site is:

Red Spark, LP

160 Pine Street, Suite 320

Harrisburg, PA 17101

USA

privacy@red-spark.com

If you use the Site, you acknowledge that your personal data is being processed on the basis of your consent and that information gathered through the Site may be transferred to, and used and stored in, the United States.

You hereby consent to the processing of your personal data as described in this Policy, including the transfer of your personal data to, and its use and storage in, the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You may withdraw your consent at any time by following the instructions in the Accessing/Updating/Deleting Your Personal Information section below, but this will not affect the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the Site. You have the right to file a complaint relating to the processing of personal data with a supervisory authority.

Further, you consent to the use of your name in advertising or marketing materials, as further described in the "How We Use Your Information: Site Users" section below.

Information We Collect

The following is a summary of the types of personal and non-personal information we may collect from or about Site users.

Site Users and Voluntarily Provided Information. We collect personal information on the Site when you utilize the Site (referred to herein as a "Site User") or otherwise choose to provide personal information to us, such as through our contact form. Personal information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: personal name (first and last) and business entity name and/or title with the applicable business entity, as well as your personal and/or business e-mail address, mailing address, business, personal and/or mobile telephone numbers, fax number, and/or any other information requested on the applicable Red Spark webpage. Additionally, we may collect email, phone call, and messenger/chat content if you choose to communicate to us. We also may collect certain technical and usage information from Site Users, such as information typically contained in a web server's log files or analytics program, including without limitation: IP address, browser type and version, operating system, geographic location, referral information, click-stream data, device identifier, unique identifier, HTTP header, including referral URL, etc. Unless otherwise required by applicable law, such as the GDPR, we treat this information as non-personal information. For additional detail about these practices, please see the section below entitled "Site User Behaviors Collected With Cookies, Web Beacons and Other Web Technologies." Furthermore, we may collect server and individual activity information so that we can provide our products and services to Site Users. Red Spark may also collect information from Site Users when you voluntarily provide it to Red Spark through other means (for example, by signing up for an email newsletter, filling out a registration offer, or by other means of online or offline surveys, order forms, or registration pages operated by Red Spark or third parties (collectively, a "User Form"). In a User Form, Red Spark or a third party may offer you incentives in exchange for registration or providing information about yourself, such as name, email address, street address, zip code, telephone numbers, birth date, gender, occupation, and employment information (together, "User Information"). Completing the User Forms is voluntary and you are under no obligation to provide User Information.

Site User Behaviors Collected with Cookies, Web Beacons, and Other Web Technologies.Red Spark uses cookies, web beacons and other web-based technologies to associate certain Internet-related information about you, such as your IP address and what web browser and operating system you are using, with certain of your online behaviors, such as opening or clicking on particular content or visiting a particular page on the Site. Additionally, Red Spark may use other new and evolving sources of information and information gathering in the future (together with cookies, web beacons and similar technologies, "Web Technologies"). We may use Web Technologies to collect certain information about individuals to help us ensure that the content we serve are targeted. For example, we may collect, without limitation, information related to content that were delivered to you and that you clicked on, along with your browsing behavior and other click-stream data. Information collected through Web Technologies is referred to below as "Technology Information." Unless otherwise required by applicable law, such as the GDPR, we treat this information as non-personal information.

(a) Cookies. A cookie is a small amount of data stored on the hard drive of your computer that allows your computer's browser to store your preferences and allows Red Spark to identify your IP address with corresponding information in Red Spark's database. Cookies, by themselves, do not tell us your email address and similar individual identifying information, but may contain such information as date and time of your website visit, session identification number and registration information. We use cookies to understand Site usage and to improve the content and offerings on the Site.

You may set your browser to warn you that cookies are in use, or to block the use of certain cookies. Most browsers are set to accept cookies. If your browser is not set to accept cookies, certain uses of the Site may require you to go to your browser user preferences to enable cookies. Each browser is different, so check the ''Help'' menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser. To find out more about cookies, please visit www.cookiecentral.com.

(b) Web beacons. A web beacon is programming code used to display an image on a web page and can also transfer an individual's user identification to a database and associate the individual with previously acquired information about the individual. Web beacons enable us to track certain websites you visit or content you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at http://www.webopedia.com/TERM/W/Web_beacon.html.

(c) Where Technology Information is Collected. Technology Information may be collected directly from the Site or through Red Spark-delivered marketing materials.

(d) Outside Information. Red Spark may lawfully receive information about you from third parties, such as information located in public databases.

(e) No Information Collected from Children Under 13. Please be advised that we do not knowingly solicit or collect personal information from children under age 13, nor do we knowingly market our products or services to children under age 13. If we become aware that a child under age 13 has provided us with personal information, we will delete it from our database. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us at privacy@red-spark.com.

How We Use Your Information: Site Users

We use your personal information primarily for administrative purposes pertaining to your use of the Site and customer management purposes, including without limitation: (a) providing reports, customer service, newsletters, RSS feeds and other information, products and/or services that you have signed up for or have otherwise agreed to receive; (b) operating the Site; (c) sending you information regarding the Site; (d) displaying content that is customized to your preferences; (e) contacting you when necessary regarding your inquiries and/or operational updates to our Site; and (f) for validation, suppression, content improvement and feedback purposes. Unless you indicate a preference not to receive such information when you utilize or contact us through the Site or subsequently, we may also send you surveys and marketing communications to inform you of new products or services or other information or offers that may be of interest, and/or updates about Red Spark. These surveys, marketing communications, or updates may come from Red Spark or our service providers. If you do not wish to continue to receive surveys, marketing communications or updates, you may indicate this preference by following the "unsubscribe" or "opt-out" instructions included within each email communication, or by other written request to Red Spark. Please keep in mind that, even if you choose not to receive these communications, you may continue to receive transactional or account communications (e.g., confirmation emails) and other communications that are required or permitted by applicable law.

You also agree that we may also use your name, company name and logo in advertising or promotional materials to refer truthfully to you as a Site User.

We use non-personal information primarily for internal research and analytics to improve our Site and our services.

Disclosure of Your Personal Information

We do not sell, rent, lease or disclose your personal information collected by the Site to unaffiliated entities, except in the limited circumstances listed below. Red Spark may transfer or disclose information to our affiliated entities, that is, entities that control, are controlled by, or are under common control with Red Spark, for marketing and other purposes at our discretion.

We may disclose your personal information to third-party service providers who perform services on our behalf. For example, we may engage other companies as data subprocessors that handle and process your personal information for the following purposes: to handle the processing of payments, to detect and protect against fraud, to provide data storage and management, to assist in marketing Red Spark's products or services, to conduct audits, to provide web analytics and business intelligence, to provide customer support, to send email and platform alerts, to provide customer surveys and messaging services, and to provide hosting, design, development and other operations which make our Site work. Other third-party service providers may help us communicate with you through electronic mail, direct mail or telephone communication. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as Red Spark, including not using it for any improper purpose.

We may also make your personal information available to non-affiliated third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary under the following circumstances:

• When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or other legal process);
• If we believe your actions violate any law, regulation, this Privacy Policy or any other agreement by which you are bound, or if you threaten the rights, property or safety of the Site, our service providers, suppliers, customers or users, or any other party;
• If, in our sole discretion, we believe such disclosure to be necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets, to defend our interests and/or to comply with our legal and regulatory obligations;
• To cooperate with law enforcement authorities, a court or administrative agency, or other governmental authority in connection with an investigation or where otherwise required or permitted by applicable law; and
• In the event of a bankruptcy, merger, acquisition, transfer of control, joint venture, sale of assets or other strategic business transaction or event involving us and/or our related companies.

Disclosure of Non-Personal Information

In addition to the foregoing, Red Spark may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons. For example, we may provide our Site Users with aggregate, anonymous non-personal information about individuals, including, without limitation, demographic data. This aggregate data allows us to create anonymous groups that our partners use to identify business opportunities.

Accessing/Updating/Deleting Your Personal Information

If you would like to delete or update the personal information that we have collected from you, simply send your request via e-mail to privacy@red-spark.com. Additionally, if your personal information is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, the right to object to processing of personal data, and the right to data portability. Please send e-mail to privacy@red-spark.com for more information.

We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

To unsubscribe from Red Spark or Site User email lists, click the link included in the footer of any message delivered by Red Spark or a Site User and follow the instructions provided, or contact us in writing.

Notwithstanding the foregoing, even if you unsubscribe from marketing emails, we may continue to contact you for the purpose of communicating information relating to your use of the Site and Red Spark's products or services, as well as to respond to any inquiry or request made by you.

If you do not request that we delete your personal information, we will retain it pursuant to our internal data retention and deletion practices as dictated by valid business and legal reasons for retaining such information. For example and without limitation, personal information provided to us by Site Users will be retained as long as such Site Users continues to communicate with us, and personal information relating to advertisers or publishers of our network will be retained as long as such individuals maintain an account with our advertising platforms, or as required under the applicable commercial agreements between Red Spark and those individuals.

How We Protect Your Personal Information

We know it takes confidence and trust to share personal information online. We endeavor to keep your confidence and maintain your trust by protecting your personal information. To that end, we maintain reasonable standards of security and confidentiality. Red Spark's computers have security measures, such as firewalls, to protect against the loss, misuse and/or alteration of the information under Red Spark's control. Red Spark also maintains physical and procedural safeguards to protect information under our control and to restrict access to those employees and agents who have a need to know in order to provide services to you and/or operate our business.

Notwithstanding such measures, Red Spark cannot guarantee that its security measures will prevent its systems and computers from being illegally accessed and the individual information on them stolen or altered. Despite our efforts, as with most Internet sites and businesses, it is possible that third parties may unlawfully intercept or access transmissions of private communications and/or unlawfully gain access to protected computers. No method of data collection, transmission or storage is 100% secure, and we cannot warrant such absolute security. Whenever you provide personal information online, you accept this risk, including when you share your personal information with us and our affiliated entities.

Notwithstanding these inherent risks, we make a concerted good faith effort to ensure that your personal information is protected by maintaining the reasonable standards of security and confidentiality mentioned above.

Privacy Practices of Third Parties

Third Party Web Technologies.Site Users as well as other partners and advertisers who provide Site analytics, may use their own cookies, web beacons and other Web Technologies to collect information about you. Red Spark has no control over third parties' use of such Web Technologies.

Links to Third Party Websites. The Site and e-mail messages transmitted by Red Spark on its own behalf or on behalf of its Site Users may contain links to third-party websites ("Third Party Websites"). Please be aware that Red Spark is not responsible for the privacy and security practices of Third Party Websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each and every website that you visit. This Policy applies SOLELY to information collected by Red Spark and/or the Site.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the rest of this Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used herein.

Categories of Personal Information:

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked directly with a particular consumer or device ("personal information"). Specifically, Red Spark's website has collected the following categories of personal information from its users within the last twelve (12) months:

For the purposes of the CCPA, personal information does not include the following categories:

• Publicly available information from federal, state or local government records.
• Aggregated or deidentified consumer information.
• Information excluded from the CCPA's scope, including:
• Protected or health information that is collected by a covered entity governed by the Confidentiality of Medical Information Act or the Health Insurance Portability and Availability Act of 1996.
• Information covered by industry specific privacy laws including the Fair Credit Credit Reporting Act, the Gramm-Leach-Bliley Act, the Driver's Privacy Protection Act of 1994 and the California Financial Privacy Act.

Sources of Personal Information:

Submitted by You: We may collect personal information from you through your direct submission of such personal information to us through a form on a website, or through email or other direct communication from you to us.

Indirectly: We may also collect personal information about you through, including certain online activities through Web Technologies as described elsewhere in the Policy.

Third Parties: We may also collect personal information about you from third-party business partners.

Purpose for Collecting Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• processing payments;
• providing reports, customer service and other information or products you have signed up for or agreed to receive;
• operating our network;
• sending you information regarding our network (including surveys or marketing communications);
• displaying content customized to you;
• tracking your compliance with our terms and conditions;
• contacting your regarding your account or changes to our Site; and
• for validation, suppression, content improvement and feedback purposes.
• to personalize your experience and ensure that the advertisements we serve are interesting to people who see the advertisements
• research and internal product optimization and development
• in response to law enforcement requests and as required by applicable governmental regulation, law or court order
• for other purposes described to you at the time of collection of your personal information
• for other purposes permissible under the CCPA.

Red Spark will not collect additional categories of personal information, or use such personal information in any way besides the uses described above without providing notice.

Sharing Your Information

Please see the "Disclosure of Your Personal Information" section above.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A
• Category B
• Category D
• Category F
• Category G
• Category K

We disclose your personal information for a business purpose to the following categories of third parties:

• Subsidiaries and affiliates
• Contractors and service providers
• Data aggregators
• Third parties with whom we partner to offer products and services to you.

Sale of Information

In the preceding twelve (12) months (as of the most recent update to this Policy), we have not sold personal information. However, we respect and understand that you may still want to ensure that your personal information is not sold. Therefore, if you would like to proceed with a "Do Not Sell My Personal Information" request, and opt-out of any future collection of your personal information, please complete the form here Do Not Sell My Personal Information.

Your Rights and Choices under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Red Spark disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Red Spark delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Writing us at:

Red Spark, LP

c/o Legal Department

3675 Market Street, Suite 900

Philadelphia, PA 19104

• Emailing us at privacy@red-spark.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we reserve the right to offer you certain financial incentives, only as permitted by the CCPA, that can result in different prices, rates, or quality levels. Any such financial incentive will reasonably relate to the value of your personal information and contain written terms that outline the material aspects of the program. Any participation in such a program requires your prior opt in consent, which may be revoked by you at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@red-spark.com

Contact Us

If you have any questions regarding this Policy, or would like more information on our privacy practices, please contact us at privacy@red-spark.com.