RedSky Strategy, LLC and our partner agencies (collectively, “Redsky,” “our,” or “we”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- In email, text, and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- Through third party business partners we work with to offer, provide, and improve our services to our clients.
Please read this policy carefully to understand our policies and practices regarding how we may collect, use, maintain, protect, and disclose your information. If you do not agree with our policies and practices, you may choose not to use our Website, or you may choose to exercise your rights as disclosed in this policy.
Not all partner agencies collect, disclose, handle, process, sell, share, transfer, or use every category of personal information mentioned in this policy. Instead, this policy represents a good faith representation to the best of our knowledge of what Redsky and our partner agencies collect, disclose, handle, process, sell, or share collectively about individuals. If you have questions about a specific agency’s personal information practices, please contact firstname.lastname@example.org or the specific agency.
Information We Collect
We (or our partners) have collected the following categories of personal information from individuals within the last twelve (12) months:
- Identifiers such as real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.
- Personal information categories listed in the California Customer Records statute, California Civil Code § 1798.80(e), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Protected classification characteristics under state or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Commercial information such as records of products or services purchased or considered or consuming histories or tendencies.
- Biometric information such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Internet activity such as browsing or search history, and interaction with websites, applications, or advertisements (e.g. through cookies).
- Geolocation data such as physical location or movements.
- Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information such as current or past job history or performance evaluations.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Inferences drawn from other personal information such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Additional information collected from our employees or job applicants within the last twelve (12) months as necessary to comply with applicable law or provide employment related benefits includes: government issued ID number, age, citizenship, ethnicity, gender identity or expression, medical condition, military or veteran status, current or past job or educational history, licenses or certifications, work style and motivators, contact information for references, and bank account information (for payroll / direct deposit purposes).
Information Collected Through Automatic Data Collection Technologies
- We collect information through the use of “cookies” and similar technologies, such as tracking pixels, to understand how you navigate through and interact with our Website, to learn what content is popular, to enhance the Website and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your preferences, and to collect certain usage, device, and location information, as described above. The technologies we use for this automatic data collection may include:
- Flash Cookies.Flash cookies are being discontinued. However, for the time being, certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons.Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit RedSky, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity). We and our vendors also use these technologies and the information collected by them for data analytics purposes.
Our Website is not always designed to respond to “do not track” signals received from browsers.
Information Collection Sources
We obtain the personal information listed above:
- Directly from you, including when you complete forms for us on and off our Website, or in correspondence between RedSky and you.
- Through products and services you purchase from or through us.
- From your employer or your contacts, such as if the organization or someone you know submits a request on your behalf that may include your personal information.
- Through marketing events you register for or attend.
- Through public sources, such as LinkedIn or professional social or marketing websites.
- From our vendors and business partners.
- From observing (technologically) your interactions with our Website or applications.
Employees or job applicants may provide additional information listed above through job applications, benefits enrollment, and payroll or direct deposit enrollment.
Using Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a service or ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate new services offered to you.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments, and provide related products or services or prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To provide, support, personalize, and develop our Website, products, and services.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
- In any other way we may describe when you provide the information.
We will not collect additional categories of personal information or use your information for any materially different, unrelated, or incompatible purposes without providing you notice. We may also use personal information to contact you about our own and third-parties’ goods and services that may be of interest to you. We may use non-personal information for any business purpose.
Sharing Personal Information
Generally, we do not sell personal information. However, certain laws define selling very broadly to also include renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information for money or other valuable consideration.
We may disclose your information to a third party for one or more of the following business purposes:
- Performing services or servicing accounts.
- Processing or fulfilling orders and transactions.
- Providing employee benefits or analytic services.
- Maintaining or improving the quality of products or services we offer.
- Detecting security incidents, protecting against malicious activity, and prosecuting those responsible.
We aim to make these business purpose disclosures to third parties pursuant to written contracts specifying the purposes, requiring the recipient to keep the personal information disclosed confidential, and prohibiting use of the disclosed information for any purpose except under the contract. We use our best efforts and due diligence to select, manage, and oversee our service providers.
We may disclose aggregated information that does not identify any individual, without restriction. We may also share non-personal information without restriction.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply any agreements between RedSky and you, if applicable.
- As we believe necessary to protect the rights, property, or safety of RedSky, our affiliates, our customers, or others.
- In the event of sale (of some or all of our assets), transfer, merger, reorganization, dissolution, or similar event involving our business (including in contemplation of such transactions), your information may be among the shared or transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions.
Your Rights and Choices
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising.
- Marketing and E-mail. RedSky respects the rights users give us when opting to receive email communications and enforces internal policies to preserve those rights. It is our objective to retain the long-term ability to continue to communicate with our users.
- Opting Not to Register or Provide Personal Information. If you choose not to register or provide Personal Information, you can still visit most areas of Redsky’s Website; however, you will not have access to areas that require personal identification.
California and Nevada residents may have additional personal information rights and choices.
Your Nevada Privacy Rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request using the Contact Information below. However, we do not sell data triggering that statute’s opt-out requirements.
Your California Privacy Rights
The CCPA provides California residents with specific rights regarding their personal information. If applicable, this section describes your CCPA-based rights and explains how to exercise those rights. The section will not apply, however, if RedSky does not collect any personal information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available).
Also, please note, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) and workforce-related personal information (“HR personal information”) from some of its requirements.
Right to Know and Data Portability
California consumers have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “Right to Know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you (disclosed above).
- The categories of sources of the personal information we collected about you (disclosed above).
- Our business or commercial purpose for collecting that personal information (disclosed above).
- The categories of third parties with whom we share that personal information (disclosed above)
- If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
- If we sold your personal information, we will identify the personal information categories that each category of recipient purchased.
- The specific pieces of personal information we collected about you (also called a “data portability” request).
Right to Delete
California consumers have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “Right to Delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allows us to retain the information applies. We will delete from our records or deidentify personal information not subject to a lawful exception and will direct our service providers to take similar action.
Right to Opt-In or Opt-Out of Sale
RedSky does not generally sell any personal information. However, the CCPA broadly defines selling to also include renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
Based on this definition, some partner agencies may “sell” personal information under the CCPA.
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by email at email@example.com.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Subject to some exceptions, California consumers have the right not to be discriminated against based on the consumer’s refusal to provide a business with personal information, including:
- Denying goods or services.
- Charging (or suggesting you may receive) different prices for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing (or suggesting you may receive) a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Currently, we do not provide any financial incentives.
Exercising Your Right to Know or Delete
To exercise your rights to know, including your right to request data portability, or delete described above, please submit a request by email at:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You or your authorized agent may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide sufficient information, which will likely need to match information we previously collected from you, that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (“Authorized Agent”). In some instances, we may ask you to provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. For requests seeking particularly sensitive information, we may require additional proof of identification.
If you would like, you may designate an Authorized Agent to make a request under the CCPA on your behalf. We will deny requests from agents that do not submit proof of authorization from you. If you designate an Authorized Agent to make a request under the CCPA, to verify that an authorized agent has authority to act for you, we may require:
- A copy of a power of attorney or require that you provide the authorized agent with written permission.
- You to verify your own identity with us directly.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it, except for record-keeping purposes. We will delete this information as soon as practicable after complying with the request.
Other California Privacy Rights
Shine the Light Law
RedSky does not make any disclosures of personal information to third parties for their direct marketing purposes, but California’s “Shine the Light” law found in Section 1798.83 of the Civil Code, permits users of our Website that are California residents to request information about such disclosures, if applicable. To make such a request, please contact us at info.redskystrategy.com
Children Under 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
California residents younger than 16 may have additional rights regarding the collection of their personal information. We do not knowingly sell any personal information about minor children.
If you have any questions or comments about this notice, the ways in which Redsky collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: