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Welcome to the Red Lotus (“Red Lotus,” “we”) web site at http://www.Red Lotus.com (the “Site”). Red Lotus is a digital advertising company and values the privacy of consumers who visit the Site as well as web and mobile sites and applications where our technology is enabled (“Users,” “you”). Red Lotus uses technology to gather information and optimize the delivery of digital advertising (the “Technology”).
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Red Lotus collects and processes your personal data through your use of this website, including any data you may provide through this website when you apply for a product demo.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Red Lotus is the controller and responsible for your personal data (collectively referred to as “Red Lotus”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are: Red Lotus 20 North Audley, Street, #201, London, W1K 6LX, UK.
Support: [email protected] Lotus.com
Data Privacy Officer (DPO)
Name or title of DPO: Red Lotus DPO
Email address: [email protected]
Postal address: Red Lotus 20 North Audley, Street, #201, London, W1K 6LX, UK.
You have the right to make a complaint at any time the Data Protection Authority. You can find contact details of your National Data Protection Authority online at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.html
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us or our DPO in the first instance.
CHANGES TO THE PRIVACY NOTICE AND OUR DUTY TO INFORM YOU OF CHANGES
This version was last updated on May 25, 2018 and historic versions can be obtained by contacting us.
The data protection law in the EU will change on May 25, 2018. Although this privacy notice sets out most of your rights under the new laws. We are still formalizing processes for responding to certain types of request under the new GDPR. You can contact the Red Lotus DPO in the first instance for any queries. We will be updating our systems and processes as an ongoing project and this privacy notice may be updated with these changes at any time
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. OUR ADVERTISING SERVICES & DATA WE COLLECT ABOUT YOU
Red Lotus is not an ad network or a data broker. It is a digital advertising technology platform. By “Platform,” we mean a technology that provides tools for advertisers, or buyers, to purchase ad space and for website and mobile application publishers, or sellers, to sell their ad space in the most efficient way possible. Users benefit from targeted advertising by receiving more interesting and relevant advertisements, while advertisers benefit through the more efficient delivery of advertising to interested Users.
Our targeting options are based on non-personally identifiable data that is collected over time and may range from sending an advertisement to a User based on such factors as a User’s interests, similarities to other Users, or general geographic location. This data may be used to identify and predict the sites and groups of Users that are most likely to create a response to an advertiser’s campaign.
If you prefer not to have Red Lotus tailor online advertising to your interests, you may opt out at any time by one of the following methods: Opt out of Red Lotus user interest targeting cookie by clicking “OPT OUT HERE”. Please note that if you delete your cookies, change browsers, or use a different computer, you will need to opt out again. Read more at: https://Red Lotus.com/privacy-policy/
Personally identifiable data, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, nationality, date of birth, place of birth, gender, passport or ID document number, photo, issue date, expiry date and other information provided in passport or ID document scan copy.
Contact Data includes residence address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, device type, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
The Red Lotus Site is generally intended for use by businesses, advertisers, and potential partners interested in learning more about Red Lotus. You may provide to Red Lotus Identity Data (such as your name or email address) when using the Site. For example, if you are an advertiser or web publisher and use the Site to request a contact from our sales or business development department, we will ask for your name, email address and other contact information so that a Red Lotus representative can respond to your inquiry. We do not use your Identity Data for any other purpose other than responding to your request. We do not share your personally identifiable information with other organizations for their marketing or promotional uses without your express consent. Notwithstanding the above, Red Lotus reserves the right to disclose Identity Data if: (i) required by law or in the good-faith belief that such action is necessary to comply with state and federal laws; (ii) we believe, in good faith, that such action is appropriate or necessary to take precautions against liability; or (iii) such action is necessary to protect our rights or those of our Users and others.
We adhere to Digital Advertising Alliance Principles with regard to data collection and interest-based advertising. Visitors to the Red Lotus site may experience a third party engaging in data collection for such purpose, based on your browsing behavior across many sites. If you wish to control such data collection, you may visit the DAA Consumer Choice Page, where you can learn more about the value of interest-based ads, and express your preferences there. The Site is hosted in the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your personally identifiable information outside of those regions to the United States and by providing your personally identifiable information on the Site you consent to that transfer. Read more at: http://grvty.fr/1BzXR
IF YOU FAIL TO PROVIDE PERSONAL DATA
We need to collect personal data under the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to provide you identity verification services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in online forms provided on our website. This includes personal data you provide when you:
create an account on our website;
submit your information for identity verification
Automatically Collected Information. We may also collect a variety of information from your browser or computer using the Technology, including “pixel tags,” “clear gifs,” or “web beacons.” This “automatically collected information” may also include request-based information which is passed to us by the User’s computer browser with every request and is stored without any personally identifiable information. Examples of this include your web browser type, the web sites that you visit just before or just after visiting a web site, and the dates and times that you visit a web site. We may also collect session information relating to Users and specific ad campaigns, which is used for frequency capping, or limiting the number of times a User sees a specific ad; and the targeting of Users based on their specific interests. If you are using a mobile device and viewing a website that utilizes our Technology, we may also use the Apple IFA, Android Advertiser ID, or other non-personally identifiable device information that uniquely identifies individual smartphones or mobile devices (collectively, “IDFA and Android ID”) in order to authenticate the user session. This IDFA and Android ID functions similarly to a persistent cookie to make it possible to authenticate the user without the need for a password. Read more at: https://Red Lotus.com/privacy-policy/
Click Information. We may receive non-personally identifiable information when you click on or otherwise interact with ads deployed using our Technology, including when you indicate a “like” or “share” the ad by clicking on a button near the ad. The information received by us may include information about the ad that was clicked on, the web page, or other session-based and request-based information as described above. We may also receive information regarding any links that you may click on that are associated with ads deployed using the Technology or any links that you share or receive from third parties related to those ads. Read more at: https://Red Lotus.com/privacy-policy/
Information from Tr.im. We may receive non-personally identifiable information when you click on or use our sharing tools on websites that use our Tr.im sharing service. When a user accesses a webpage that contains our sharing tools or utilizes our link shortening or video embedding services, we may add a cookie to the user’s browser to record information on websites that the user has visited, search terms that they have entered, or connections between non-personally identifiable cookies, but strictly in a non-personally identifiable profile. For our video embedding services, we may also track information related to the videos that you share, including social statistics and information relating to the parties accessing the video, but only as a non-personally identifiable profile. We may also collect the IP address and ZIP Code of any devices that access URLs shortened by our services, information about how the shortened URLs have been shared, and the date and time of the website access using the shortened URL. We may use this information to customize and send more relevant advertisements to that user, based upon the collected information, as described below in the section entitled, “How We Use and Disclose Information.” We do not scan the title or the content of any messages you send through our services. Read more at:https://Red Lotus.com/privacy-policy/
Information Acquired from Other Sources. We may acquire non-personally identifiable data from third party sources, including through websites that use our Technology. This data may be used for a variety of purposes, including to update existing User profiles, to provide our clients and others with aggregate information about traffic and site usage in our advertising network, and other uses as described below in the section entitled, “How We Use and Disclose Information.” We do not share, rent or sell any of this non-personally identifiable data and require these third party sources to comply with applicable industry and legal standards. Read more at: https://Red Lotus.com/privacy-policy/
4.HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Please see information below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Customers. Red Lotus will collect customer identifying information for contractual reasons. This is so we can contact you and communicate with you and your company efficiently.
General. Red Lotus uses the information collected by the Technology to tailor advertising to you more effectively. The aim is for you to see ads which you are more likely to be interested in. We do this by comparing the information in a non-personally identifiable profile against our selection of ad campaigns and choosing the most suitable advertisement. In general, Red Lotus can only create these profiles and display ads to you when you visit a web site within our network. This data is collected for a lawful and legitimate reason so we can perform our contracts with our customers and also customize advertising to you.
Action Attribution. To gain a greater understanding of a web site’s performance or a User’s general interests, we use a variety of technologies to determine which web sites in our network the User has visited previously and/or where the User clicked on an advertisement. By using this information, we can calculate which web sites and/or which broad interest characteristics of Users are most likely to respond to a particular campaign. This may be performed two ways – Performance Attribution and User Interest Profiling. This data is collected for a lawful and legitimate reason so we can perform our contracts with our customers and also customize advertising to you.
User Interest Profiling. To create a User interest profile, we observe which web sites within our network Users have visited and determine what topics are covered by these web sites. This information is combined to generate a non-personally identifiable interest profile for specific browsers to better target our ads to Users. For example, if a User visits a sports site within our network, we may classify them as broadly interested in that sport and potentially interested in purchasing sports gear. That information may be provided to our advertising partners to allow them to better tailor their ads to specific Users. This data is collected for a lawful and legitimate reason so we can perform our contracts with our customers and also customize advertising to you.
Tr.im. If you use our Tr.im sharing service, we may provide our third party partners with non-personally identifiable metrics and analytics about information and websites that you access. For example, if you click on a curated link hosted by one of our partners, our partner may receive non-personally identifiable information about the fact that you have accessed that website, including but not limited to the date and time of such access, the website visited, and the IP address and ZIP Code of the device used to access the link, but strictly in a non-personally identifiable profile. This data is collected for a lawful and legitimate reason so we can perform our contracts with our customers and also customize advertising to you.
Service Providers. Red Lotus works with authorized service providers to provide website hosting, maintenance, and other services for us. To the extent it is necessary for these service providers to complete their obligations to us, these service providers may have access to User information. However, we contractually require these service providers to safeguard User information and generally limit their use of User information to the purpose for which it was shared. This data is collected for a lawful and legitimate reason so we can perform our contracts with our customers and third parties and helps us better provide services
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out above.
We will get your express opt-in consent before and if we share your personal data with any company outside the Red Lotus group of companies for marketing purposes.
8.CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9.WHERE WE STORE YOUR INFORMATION
10.DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary only after your explicit consent to such disclosure.
Specific third parties such as service providers acting as processors based in the EU who provide identity verification services.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Numerous studies have established that data stored in the cloud is less likely to be lost, deleted or leaked than data stored on a personal computer. All our data is fully encrypted at rest and in transit, and we employ state-of-the-art firewall and back-up technology. All our data is continuously backed up in several high security access-controlled data centers in different locations.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
Platform Data is stored using generally accepted security standards. It is usually aggregated or deleted within 30-60 days, but may be retained in the Platform for up to 18 months from the date of collection before aggregation or deletion. Aggregated data is used for reporting and analysis, and may be stored in the Platform for up to 2 additional years. When clients remove their data from the Platform, their own privacy policies and applicable laws, rules, or regulations govern their storage and retention of data. Red Lotus maintains all server log data and stored data for a period of 24 months to comply with audits, court order or law enforcement inquiries. After 24 months all of the stored data is destroyed. Summarized data is kept indefinitely. Summarized data is aggregated statistical data (impressions, clicks, and conversions) used for financial reporting purposes. Read more at:http://grvty.fr/1BzXR
13.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please Contact us.
14.NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
15.WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
16.TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the Red Lotus Group acting as processors and provide IT and system administration services.
EXTERNAL THIRD PARTIES
Other companies acting as processors based in the EU or outside EU, or our customers who use non-personal identifying data to provide customized advertising services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.