Privacy Policy

1. Introduction

Red e App, Inc. d/b/a RedeApp (“RedeApp,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information entrusted to us. This Privacy Policy explains how RedeApp collects, uses, discloses, stores, transfers, and otherwise processes personal information when individuals access or use our websites, mobile applications, software platforms, products, services, communications, and related offerings (collectively, the “RedeApp Services”).

RedeApp provides enterprise communication, workforce engagement, workflow automation, identity management, and artificial intelligence-enabled collaboration tools designed to help organizations communicate with, support, and engage employees, contractors, and other authorized users. The RedeApp Services include messaging, broadcasts, communities, workflows, file sharing, mobile applications, integrations with third-party systems, administrative tools, analytics, and AI-enabled functionality, including features offered under the Shelbe AI platform.

This Policy applies to information collected through:

• RedeApp website;
• RedeApp mobile applications;
• RedeApp hosted software and web applications;
• customer support and electronic communications relating to the RedeApp Services;
• demonstrations and sales interactions; and
• any other products or services that reference this Privacy Policy.

This Privacy Policy does not apply to:

• third party websites or applications that are not controlled by RedeApp;
• information processed solely on behalf of customers under separate contractual arrangements (except as described herein); and
• offline information collected outside the ordinary course of providing the RedeApp Services.

2. Definitions

For purposes of this Privacy Policy:

Administrator means an individual authorized by a Customer to configure, manage, supervise, or administer the Services on behalf of the Customer.

AI Services means any artificial intelligence, machine learning, natural language processing, generative AI, recommendation engine, automation, or related functionality provided by RedeApp, including Shelbe AI.

Customer means an organization that licenses or otherwise receives the Services from RedeApp.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. The meaning of Personal Information includes “Personal Data,” “Personal Information,” or similar terms under applicable privacy laws.

Services means the RedeApp Services, as defined in Introduction above, and is used interchangeably with that term in this Privacy Policy.

User means any individual who accesses or uses the Services.

User Content means messages, communications, documents, files, images, videos, comments, posts, broadcasts, workflow submissions, AI prompts, AI-generated responses, or other information submitted through the Services.

3. Scope of This Privacy Policy

Because RedeApp primarily provides business-to-business software, much of the Personal Information processed through the Services is provided by or on behalf of Customers. Accordingly, RedeApp may process Personal Information in different capacities depending upon the circumstances.

A. Information Controlled by Customers

When an organization licenses the Services, that organization generally determines:

• which individuals receive accounts;
• what information is uploaded;
• how long information is retained;
• who may access information;
• administrative permissions;
• organizational settings;
• deletion policies; and
• other configuration choices.

In these situations, RedeApp processes Personal Information on behalf of the Customer pursuant to applicable agreements, including any applicable Data Processing Addendum. Individuals seeking to exercise privacy rights relating to Customer controlled information should first contact the applicable Customer.

B. Information Controlled by RedeApp

RedeApp independently controls certain Personal Information, including information relating to:

• website visitors;
• prospective customers;
• marketing communications;
• event registrations;
• customer support;
• billing;
• security;
• fraud prevention;
• product improvement;
• legal compliance; and
• operation of our business.

This Privacy Policy primarily governs RedeApp’s processing of Personal Information in these capacities.

4. Acknowledgment & Acceptance of Terms

By downloading, registering with, accessing, or using RedeApp Services, you acknowledge that you have read and understood, or have had the opportunity to review, this Privacy Policy and agree to be bound by it. If you do not agree with our policies and practices, do not use our Services and you should discontinue use of the Services. This Privacy Policy forms part of the information governing your use of the Services and should be read together with the applicable Terms of Service, customer agreement, Data Processing Addendum, and any other agreements governing your use of the Services. This Privacy Policy may change from time to time (see Changes to this Privacy Policy). Your continued use of RedeApp Services following the effective date of an updated Privacy Policy is deemed acceptance of, and constitutes your acknowledgment of, the revised Privacy Policy to the extent permitted by applicable law. Where applicable law requires your affirmative consent to material changes, we will obtain that consent as required by applicable law. Your use of the Services is also governed by the RedeApp Terms of Service. Some Customers enter into additional written agreements with RedeApp that address privacy or data protection matters. Where such an agreement conflicts with this Privacy Policy with respect to information processed for that Customer, the executed agreement controls to the extent of the conflict. No executed agreement may reduce the protections this Privacy Policy extends to Users; where an executed agreement provides additional protections, it controls to the extent of the addition. This Privacy Policy otherwise describes RedeApp’s practices with respect to all Users of the Services.

5. Information We Collect and Receive

A. Information You Provide

The categories of Personal Information we collect depend upon how you interact with the Services.

• Profile or account information, including your full name, company or organization name, employer, job title, department, physical business address, business email address, personal email address (where permitted), telephone number, profile photograph, account credentials, and authentication information.
• Communications information including information you provide to us by submitting forms in the RedeApp Services. This includes information you provide when you register to use the RedeApp Services, post materials, and request further services. We may also ask you for information when you report a problem with the RedeApp Services. We also collect records of your correspondence (including email addresses and phone numbers), if you contact us. This also includes survey responses, feedback, and marketing preferences you provide to us.
• Billing and Transaction Information. Customers and Administrators who purchase a paid plan provide billing information, including billing contact name, billing email address, billing address, plan and subscription details, and transaction and invoice history. Payment card details are collected directly by our third-party payment processor and are not collected or stored by RedeApp. RedeApp receives only limited information from the processor, such as a payment method reference, the card brand, the last four digits, and the expiration date. Users do not purchase, pay for, or subscribe to the Services, and the Services do not offer in-application purchases.
• Health-Related Information. RedeApp does not solicit, require, or request health information from Users. Users may choose to include health-related information in User Content, in which case it is handled as User Content in accordance with the applicable customer agreement and the Customer’s configuration of the Services. Where a Customer’s use of the Services involves Protected Health Information, RedeApp’s handling of that information is governed by an executed Business Associate Agreement.
• Service-related information including information you communicate to other users through your use of the RedeApp Services. The RedeApp Services are designed to provide employers and other third-parties digital connections to their employees and teams. To make that possible, we collect, store, transmit, process, and display your content including files, messages, comments, and other materials (User Content) as well as related information which may include your profile information to make it easier to communicate with others within your company, on your teams, and in your groups.
• Unique identifiers include an online identifier, IP address, mobile device identifiers, username.
• Any other information you choose to provide.
• Sensitive Personal Information. Some of the information described above may be classified as “sensitive personal information” under applicable state privacy laws, including health-related information, geolocation data, and contents of communications. We apply heightened protections to sensitive personal information, including obtaining your consent before collecting it where required by law, limiting its use to purposes necessary to provide the RedeApp Services, and applying additional technical and organizational safeguards. You may have the right to limit our use and disclosure of your sensitive personal information under applicable law. See Additional U.S. State Privacy Rights and Your California Privacy Rights below for more information.

B. Information Provided by Customers

Customers and Administrators may provide us with information necessary to establish and administer user accounts, including:

• employee names;
• work contact information;
• departments;
• reporting relationships;
• work locations;
• employment status;
• date of birth, where provided by a Customer;
• benefits eligibility and enrollment status, such as whether a User is enrolled in employer-provided medical, dental, or vision coverage, which does not include health condition, diagnosis, treatment, claims, or medical record information;
• employee identifiers;
• scheduling information;
• organizational groups;
• permissions;
• directory information;
• role assignments;
• community memberships;
• authentication assertions or tokens received from Single Sign-On (SSO) identity providers, and confirmation of whether authentication succeeded or failed; and
• other information required to provide the Services.

Customers may configure additional data fields and transmit information of their choosing through employee data files or integrations. RedeApp does not determine or control what information a Customer elects to transmit. Customers are responsible for deciding what information they provide to RedeApp and for ensuring that they have any authority or consent necessary to provide it.

C. User Content

RedeApp collects and processes User Content submitted through the Services, including:

• direct messages;
• community discussions;
• broadcasts;
• comments;
• reactions;
• uploaded files;
• photographs;
• videos;
• audio recordings;
• forms;
• workflow submissions;
• knowledge base content;
• announcements;
• surveys;
• AI prompts;
• AI responses;
• documents;
• attachments; and
• metadata associated with such content.

User Content may include metadata attached by the device, application, or software used to create or save it. Depending on the file type and your device settings, this metadata may include the date and time content was created, information about the device or software used, and in some cases the location where the content was recorded. RedeApp does not add location information to User Content and does not use this metadata to determine or infer your location. Your device settings control whether such metadata is created.

D. Automatic Information Collection and Tracking

When you access or use RedeApp Services, we may use technology to automatically collect certain information from your device, browser, application, or network to provide, secure, maintain, and improve the Services. The categories of information collected automatically may include:

• Usage Details. We collect usage data about you whenever you access and use the RedeApp Services including traffic data, location data, other communication data, the resources that you access and use on or through the RedeApp Services, pages viewed, features accessed, buttons selected, searches performed, documents viewed, communities joined, workflows initiated or completed, communications sent, message delivery status, message read receipts, session duration, login activity, navigation paths, timestamps, referral URLs, and other interactions with the Services. Additionally, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses.
• Log Information. Our systems automatically generate logs regarding activity occurring within the Services. Log information may include IP addresses, browser requests, authentication events, error reports, diagnostic information, application crashes, security events, API activity, device events, operating system events, network performance, timestamps, and related metadata. Log information assists us in maintaining security, detecting unauthorized activity, troubleshooting errors, monitoring system performance, improving reliability, and complying with legal obligations.
• Device Information. We collect information about your mobile device and internet connection, including device type, manufacturer, model, the device’s unique device identifier, advertising identifiers (where permitted by applicable law), which RedeApp uses for product analytics rather than for advertising, push notification token, IP address, operating system, browser type and version, mobile network information, mobile carrier, language settings, time zone, application version, screen resolution, the device’s telephone number, and other technical identifiers reasonably necessary to operate the Services.
• Location Information. Depending on your device settings and your organization’s configuration, we may collect location-related information, including approximate location derived from IP address, country, state or province, city, time zone, and other coarse geographic information. If certain Services require more precise location information, we will request any permissions required by your device or applicable law before collecting such information.
• Analytics. We and our service providers may collect analytics information regarding use of the Services to understand feature usage, engagement, reliability, performance, user experience, adoption of new functionality, system capacity, operational metrics, and aggregate usage trends. Analytics information may be collected through first-party or third-party analytics technologies. Where required by applicable law, analytics technologies will be deployed only after obtaining any required consent.
• Information Obtained by Tracking Technologies or Cookies. We may use various technologies to collect information about you.

For more information, see Cookies and Similar Technologies below.

E. Information We Receive from Third Parties or Publicly Available Sources

We may receive information about you from third parties including, for example, our business partners, subcontractors, analytics providers, and service providers. If your employer or other third-party has purchased our Services, they may provide us with information about you so that we can setup and maintain your account. We may receive information from your employer or other third-party organization that we need to set up your account.

We may receive information identifying visitors to our website, including name, employer, job title, and business contact information, from third-party visitor identification and business data providers. We may use that information to contact you regarding our products and services. You may opt out of receiving such communications as described in Your Rights and Choices below.

6. Cookies and Similar Technologies

RedeApp uses cookies and similar technologies to provide, secure, maintain, analyze, and improve the Services. These technologies may include cookies (including first-party and third-party cookies), local storage, session storage, software development kits (SDKs), web beacons, pixels, clear GIFs, and similar technologies.

A. Types of Cookies and Technologies We Use

1. Strictly Necessary Cookies. These cookies are required for operation of the Services and cannot be disabled through our systems. Examples include cookies used to authenticate users, maintain login sessions, detect fraud, protect security, maintain user preferences, and operate core functionality.
2. Functional Cookies. These cookies help remember preferences and improve user experience, including language selection, display settings, notification preferences, accessibility settings, and other user-selected configurations.
3. Analytics Cookies. Subject to applicable law, we may use analytics technologies to better understand how individuals interact with the Services, including pages visited, navigation patterns, feature adoption, application performance, error reporting, and aggregate usage statistics.
4. Performance Technologies. We may use technologies that help us identify performance issues, monitor availability, diagnose technical problems, optimize application performance, and improve reliability.
5. Cookies (or mobile cookies). Cookies are small data files stored on your hard drive or in device memory that help us improve RedeApp Services, customize your experience and preferences, and understand which areas and features of RedeApp Services are most popular and account activity.
6. Web Beacons. Certain pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

We use Google Analytics to help us understand how users interact with the RedeApp Services, including how often users visit the Site, what pages they visit, and what other sites they visited prior to coming to the Site. We use the information from Google Analytics only to improve the RedeApp Services. More information about Google Analytics can be found in the Google Analytics Terms of Service and the Google Analytics Privacy Policy. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, as described in Cookies and Other Tracking Technologies below. RedeApp does not sell or share Personal Information collected through the RedeApp platform or mobile applications. On the RedeApp marketing website, third-party advertising, analytics, and visitor-identification cookies and similar technologies may involve the “sale” or “sharing” of Personal Information, as those terms are defined under applicable state privacy laws, and may be used for cross-context behavioral advertising. Where required by applicable law, these technologies operate only after you are given notice and the opportunity to exercise choice, and you may opt out as described in Your Rights and Choices.

B. Cookie Choices

Most browsers permit users to delete cookies, block cookies, limit cookie storage, receive notifications before cookies are stored, or configure browser privacy settings. Certain portions of the Services may not function properly if cookies are disabled. Where required by applicable law, RedeApp provides users with the ability to manage cookie preferences through a consent management platform or similar mechanism. For browser-level controls and third-party opt-out mechanisms, see Your Rights and Choices and Third-Party Information Collection.

C. Do Not Track and Opt-Out Preference Signals

Browser-based “do not track” (a/k/a “DNT”) signals are not standardized and we do not currently respond to or honor DNT signals transmitted by web browsers. Separately, where required by applicable law, RedeApp recognizes legally valid browser-based opt-out preference signals, including Global Privacy Control (“GPC”) signals transmitted by your browser or browser extensions, with respect to processing activities covered by applicable privacy laws. When we detect a GPC signal, we treat it as a valid request to opt out of the sale or sharing of personal information associated with that browser, as required by the California Privacy Rights Act and other applicable state privacy laws. For more information about GPC, visit https://globalprivacycontrol.org.

For more information on managing our use of these technologies, see Your Rights and Choices.

7. Mobile Application Permissions

A. Permissions We Request

RedeApp offers mobile applications that may request access to certain features or functionality of your mobile device. Depending upon your device, operating system, organization settings, and how you choose to use the Services, RedeApp may request permission to access push notifications, camera, microphone, photographs, media library, device storage, contacts, calendar, Bluetooth, location services, biometric authentication features offered by your device, network status, and other device functionality necessary to operate requested features. RedeApp accesses these permissions only as reasonably necessary to provide requested functionality or improve the Services. Information collected through these permissions is described in Information We Collect and Receive above, including under Device Information and Location Information.

B. Biometric Authentication

Where you enable biometric authentication, that authentication is performed by your device using functionality provided by your device manufacturer or operating system. RedeApp does not receive, collect, store, or otherwise process biometric identifiers or biometric information, and receives only confirmation that authentication succeeded or failed.

C. Managing Permissions

You may modify many device permissions at any time through your device settings. Disabling certain permissions may limit or prevent the operation of particular features. Your organization may also pre-configure, require, or restrict certain permissions through mobile device management or similar administrative controls. RedeApp does not access device functionality beyond the permissions granted by you or your organization.

D. Voice Input

Where you use your device’s keyboard dictation or voice input features to enter text, speech is converted to text by your device or its operating system provider before it is submitted to the Services. RedeApp does not record, receive, or store audio from voice input and receives only the resulting text. Your device or operating system provider’s handling of that audio is governed by its own privacy policy and your device settings.

8. Third Party Information Collection

A. Service Providers Operating Within the RedeApp Applications

RedeApp does not permit third parties to collect information within the RedeApp mobile applications for their own independent purposes, including advertising, cross-context behavioral advertising, or the creation of user profiles. RedeApp does engage service providers that process limited information on RedeApp's behalf in order to operate, secure, and support the applications. These include providers of crash reporting and application diagnostics, product analytics, error and performance monitoring, push notification delivery, message and verification code delivery, and automated abuse and bot prevention. Information processed by these providers may include device and application identifiers, advertising identifiers where permitted, application version and configuration information, operating system and device characteristics, diagnostic and crash data, usage and interaction events, and error and event logs. These providers act only on RedeApp's instructions, under contractual obligations that restrict their use of the information to the services they provide to RedeApp and prohibit their use of it for their own purposes, including advertising. The categories of service providers RedeApp engages are described in Sharing and Disclosure of Information below, and information regarding RedeApp's current service providers is available upon request.

B. Third-Party Technologies on Our Website

When you visit the RedeApp marketing website, third-party technologies may collect information about your device and your interactions with the site. These include technologies operated by analytics providers, advertising and remarketing platforms, session recording providers, and business data and visitor identification providers. Depending on your location and your choices, these technologies may be used to measure site usage across devices, build advertising audiences, deliver advertising to you on other websites and platforms, and identify the organization or individual visiting the site so that we may follow up regarding our products and services. Which of these technologies operate, and whether they operate before you make a choice, depends on your location and your consent selections, as described in Cookies and Similar Technologies above. A current list of the providers operating on our website is available upon request. The RedeApp application does not use advertising or analytics tracking technologies.

C. Third-Party Websites and Services

The Services may also permit users or Customers to access or interact with third-party websites, applications, integrations, products, or services. RedeApp does not control the privacy practices of third parties and is not responsible for their collection, use, disclosure, or processing of personal information. Users should review the privacy policies of third-party services before providing personal information to those services. Use of third-party services is governed solely by the applicable third party’s terms and privacy policies, and RedeApp does not own or control those services or their content, security, or data processing activities.

9. How We Use Your Information

RedeApp uses Personal Information for legitimate business purposes related to providing, operating, securing, supporting, and improving the Services. Depending on the circumstances and your relationship with RedeApp, we may use Personal Information for one or more of the following purposes:

A. Providing the Services

We use Personal Information to:

• create, maintain, and administer user accounts;
• authenticate Users and verify identity;
• provide access to the Services;
• facilitate communications between Users and organizations;
• deliver messages, broadcasts, notifications, workflows, communities, and other collaboration features;
• deliver messages and communications, including scheduled and automated communications, at the direction of a Customer or its Administrators and to recipients determined by criteria the Customer configures, which may include information contained in Customer-provided employee data;
• provide AI-enabled functionality;
• process transactions requested by Users or Customers;
• provide customer support;
• fulfill contractual obligations; and
• otherwise operate the Services.

The content, timing, recipients, and delivery schedule of such communications are determined by the Customer or its Administrators. RedeApp does not author these communications.

B. Administration and Customer Management

We use Personal Information to:

• administer Customer accounts;
• manage subscriptions and licensing;
• administer billing and payment processes;
• maintain customer records;
• communicate with Customers and Administrators;
• provide implementation, onboarding, and training services;
• respond to customer inquiries; and
• administer contractual relationships.

C. Improving and Personalizing the Services

We may use Personal Information to:

• improve existing products and services;
• develop new functionality;
• evaluate feature adoption;
• monitor performance;
• troubleshoot technical issues;
• improve accessibility and usability;
• conduct analytics;
• estimate audience size and usage patterns;
• store information about your preferences so that the Services may be customized to your interests;
• improve the speed and relevance of your searches;
• recognize you when you use the Services;
• perform testing and quality assurance;
• identify trends;
• evaluate customer satisfaction; and
• improve the reliability, security, and functionality of the Services.

Where reasonably practicable, RedeApp uses aggregated or de-identified information for product improvement activities.

D. Communications

We may use Personal Information to communicate with you regarding:

• your account, including expiration and renewal notices;
• service updates;
• maintenance notifications;
• product enhancements;
• security alerts;
• customer support;
• invoices;
• subscription renewals;
• training opportunities;
• product announcements;
• webinars;
• surveys;
• marketing communications; and
• other information relating to the Services.

If you are a network administrator or prospective customer, we may also use your information to contact you about goods and services that may be of interest to you. This may include contacting individuals identified through third-party visitor identification or business data providers regarding our products and services, consistent with Information We Receive from Third Parties or Publicly Available Sources above. You may opt out of receiving promotional communications at any time by following the instructions in Your Rights and Choices below. Operational, security, transactional, and administrative communications may continue as necessary to provide the Services.

E. Security and Fraud Prevention

We use Personal Information to:

• detect and prevent fraud;
• investigate suspected violations of our agreements;
• identify unauthorized access;
• monitor system integrity;
• detect malicious activity;
• enforce our policies;
• protect the Services;
• investigate security incidents;
• respond to cybersecurity threats; and
• comply with applicable legal obligations.

F. Legal Compliance

We may use Personal Information to:

• comply with applicable laws and regulations;
• respond to lawful requests from governmental authorities;
• comply with court orders, subpoenas, or other legal process;
• exercise or defend legal claims;
• protect the rights, property, and safety of RedeApp, our Customers, Users, and others; and
• satisfy recordkeeping, audit, tax, accounting, and regulatory requirements.

G. AI Services

Where AI Services are enabled by a Customer, RedeApp may use Personal Information to provide AI functionality requested by Users or Customers, as described in Artificial Intelligence Services below.

10. Artificial Intelligence Services

RedeApp may offer AI Services, including Shelbe AI and other machine learning, natural language processing, automation, or generative AI capabilities. The AI Services are intended to assist organizations and authorized Users by facilitating communications, knowledge retrieval, workflow automation, summarization, drafting assistance, recommendations, and similar productivity functions.

A. Information Processed by AI Services

Depending upon how the AI Services are used, RedeApp may process prompts submitted by Users, questions, instructions, uploaded documents, communications, workflow information, organizational knowledge, files, metadata, administrator-configured information, User Content, and AI-generated outputs.

B. Third-Party AI Providers

To provide AI functionality, RedeApp may utilize third-party cloud providers, artificial intelligence model providers, or related service providers. When the AI Services cannot generate a response from Customer or organizational content, they may transmit system-generated search queries derived from a User’s request to third-party search providers in order to retrieve responsive information. Where third-party providers process information on RedeApp’s behalf, they do so pursuant to contractual obligations designed to protect the confidentiality and security of Customer information, as further described in Sharing and Disclosure of Information below. Additional information regarding the providers RedeApp engages to support the AI Services is available upon request.

C. Customer Control

Customers determine whether AI Services are enabled for their organizations. Customers and Administrators remain responsible for determining what information Users may submit to AI Services and for configuring organizational policies governing the use of AI functionality.

D. Accuracy of AI Output

Artificial intelligence technologies generate responses based upon statistical models and available information, and AI-generated content may contain inaccuracies, omissions, or outdated information. AI-generated content does not constitute legal, medical, financial, employment, or other professional advice, and Users remain responsible for reviewing AI-generated content before relying upon or distributing it. Warranties, disclaimers, and limitations relating to the AI Services are governed by the applicable Terms of Service or customer agreement.

E. AI Training

Except as expressly provided in a customer agreement or with the Customer’s authorization, RedeApp does not use User Content submitted through the Services to train publicly available third-party foundation models. RedeApp may use de-identified, aggregated, or anonymized information, where permitted by applicable law and customer agreements, to improve the performance, reliability, security, and operation of the Services.

F. Responsible AI

RedeApp is committed to developing and deploying AI-enabled functionality responsibly and implements reasonable administrative, technical, and organizational safeguards designed to promote the security, integrity, and appropriate use of AI Services. Customers remain responsible for evaluating whether AI-generated outputs are appropriate for their intended use cases and regulatory obligations.

G. Automated Decision-Making and Profiling

RedeApp does not currently use personal information to engage in automated decision-making or profiling that produces legal effects concerning individuals or similarly significant effects on them. If RedeApp implements any such processing in the future, RedeApp will update this Privacy Policy to describe the logic involved, the significance and envisaged consequences of the processing, and any rights individuals may have to opt out of, obtain human review of, or contest such decisions under applicable law. Customers that configure or deploy the Services to support their own decision-making remain responsible for the lawfulness of those decisions.

11. Sharing and Disclosure of Information

RedeApp does not sell or share Personal Information collected through the RedeApp platform or mobile applications. Personal Information collected through the RedeApp marketing website may be sold or shared, as those terms are defined under applicable state privacy laws, through third-party advertising and visitor-identification technologies, and you may exercise choices regarding those activities as described in Cookies and Similar Technologies and Your Rights and Choices. RedeApp discloses Personal Information only as described in this Privacy Policy, our agreements with Customers, or as otherwise authorized or required by law.

If you are using RedeApp in your workplace or on an organization issued device, your organization will likely have its own policies in place regarding your communications and use of RedeApp. In addition to reviewing our policies, you should also check with your organization or network administrator to see what policies they have in place. RedeApp may disclose the personal information that we collect:

1. To your organization and its Administrators. Where you access the Services through an account provisioned by a Customer, RedeApp discloses to that Customer and its Administrators the information necessary to administer its network and users. Depending on the Customer’s configuration, this may include your name, username, profile photograph, bio, business email address, telephone number where you have enrolled it for multi-factor authentication, the date your account connected to the Customer’s network, your most recent activity date, the teams, groups and communities of which you are a member, whether your account is designated as a guest account, and information about the devices and browsers you use to access the Services, including browser and operating system version and device model. Administrators may export this member directory information. Administrators may also create, modify, suspend or delete user accounts; manage permissions and access; administer workflows and communities; and, where the Customer requires it, request an audit of messages sent to, from or between specified Users, or within a specified group, over a specified date range, including message attachments and images. Direct messages between Users may be included in such an audit. RedeApp does not provide Administrators with page-level navigation history. RedeApp is not responsible for a Customer’s use of information available to it through the Services.
2. To our subsidiaries and affiliates.
3. To our service providers, contractors and other third parties we employ to administer and or provide aspects of RedeApp Services for us or on our behalf. These third parties may have access to personal information, you have provided, only to perform these tasks on our behalf and are required not to disclose or use such information for any other purpose. These providers may assist with cloud infrastructure, hosting, content delivery, storage, backup and disaster recovery, security, vulnerability management, fraud prevention, authentication and identity management, single sign-on (SSO), payment processing, communications, transactional email, messaging, analytics, application monitoring, customer support, software development, workflow automation, artificial intelligence, document management, system administration, professional services, and other business operations, and are subject to contractual obligations requiring appropriate confidentiality and security protections. RedeApp requires subprocessors that process personal information on its behalf to enter into written agreements requiring appropriate confidentiality, security, and privacy protections consistent with applicable law and RedeApp’s contractual obligations. Information regarding the service providers and subprocessors RedeApp engages is available upon request.
4. To comply with any court order, law, or legal process. RedeApp may disclose information about you to government or law enforcement officials or private parties as required by law and disclose and use such information as we believe reasonably necessary or appropriate to respond to claims and legal process, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, unauthorized or harmful, or to protect the rights, property, or safety of RedeApp, our Customers, or others.
5. To a buyer or other successor. RedeApp may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal such as a merger, consolidation, acquisition, financing, investment transaction, reorganization or sale of assets or in the event of bankruptcy or receivership, in which case we will require the recipient to honor this Privacy Policy. You acknowledge that such transfers may occur and that any acquirer or successor of RedeApp or its assets may continue to use your information as set forth in this Privacy Policy. You will be notified via email and/or a prominent notice on our Site or RedeApp Services of any change in ownership or resulting change in uses of your information, as well as any choices you may have regarding your information.
6. For the purpose for which you provided the information, or any other purpose disclosed by us at the time of collection.
7. To enforce our rights arising from any contracts entered into between you and us, or between us and your organization.
8. To third-party systems that a Customer chooses to integrate with the Services, including identity providers, human resources information systems, payroll systems, scheduling platforms, productivity applications, communication platforms, and other business software. When a Customer enables an integration, RedeApp may disclose personal information to, or receive personal information from, the applicable third-party system as directed by the Customer. RedeApp is not responsible for the privacy practices of third-party services selected or enabled by Customers. Customers are responsible for evaluating and approving any third-party integrations they enable and for ensuring that their use of such integrations complies with applicable laws, contractual obligations, and organizational policies.
9. To attorneys, accountants, auditors, insurers, consultants, financial advisors, and other professional advisors, where reasonably necessary in connection with RedeApp’s business operations or legal obligations.

RedeApp may create, use, and disclose aggregated, anonymized, or de-identified information about our users and information that does not identify any individual or device without restriction, including for analytics, benchmarking, product improvement, research, reporting, and statistical analysis.

12. Your Rights and Choices

When you use RedeApp Services, you have control over a number of things with respect to your own privacy. RedeApp network administrators will have additional choices that impact the privacy of users that may not be accessible to all users, because RedeApp provides network administrators with the maximum ability to control the users from their organization.

A. Promotional Emails

You may opt-out of receiving future promotional emails from us by adjusting your account preferences. If we have sent you a promotional email, you may click “unsubscribe” link at the bottom of the relevant email. You may also send an email stating your request to privacy@redeapp.com. This opt-out does not apply to information provided by RedeApp as a result of a product purchase or other non-marketing related transaction.

B. Cookies and Other Tracking Technologies

Cookie controls, opt-out preference signals, and the effect of disabling cookies are described in Cookies and Similar Technologies above. If you do not want Google Analytics to be used in your browser, Google Analytics provides an opt-out tool, which can be found at https://tools.google.com/dlpage/gaoptout. For additional information about opting out of third-party tracking, see Third Party Information Collection.

C. Choices for Users

As an end user, you may:

• Account Information. Update or correct your account information and other settings at any time by visiting the account settings tab within RedeApp Services; and
• User Content. You can retract or remove User Content within the Services, and you can delete local copies stored on your device. Retraction and removal do not delete User Content from RedeApp’s systems. You should contact your employer or organization about additional rights you may have with respect to User Content, including permanent deletion, which is a Customer-level control described in Data Retention below.

D. Choices for Organizations & Administrators

If you act on behalf of an organization as an administrator, you may:

• Network administrators have the ability to manage and change most of the settings on behalf of the user’s organization. Administrators can also deactivate user accounts for their organization. Only an authorized representative of an organization may deactivate or delete networks, groups or accounts.
• Network administrators can export message content from users that are in their network. Message history for direct messages between users can be included in this. Depending on Customer settings, Administrators may have the ability to access, retain, export, monitor, or delete User Content in accordance with applicable agreements and organizational policies.

E. Privacy Rights and Requests

Depending upon your jurisdiction and the manner in which RedeApp processes your personal information, you may have certain rights regarding your personal information. Subject to applicable law, those rights may include the right to know whether RedeApp processes your personal information; access personal information we maintain about you; receive a copy of your personal information in a portable format where technically feasible; request correction of inaccurate personal information; request deletion of personal information; withdraw consent where processing is based upon consent; object to or restrict certain processing activities where permitted by law; opt out of processing for targeted advertising, profiling, or the sale or sharing of personal information where applicable; appeal a denial of a privacy request where required by applicable law; and designate an authorized agent to exercise rights on your behalf where permitted by law. If RedeApp processes personal information solely on behalf of a Customer, RedeApp may direct your request to the applicable Customer, which is responsible for responding to requests relating to Customer controlled information. To protect personal information, RedeApp may verify your identity before fulfilling a privacy request, and verification procedures may vary depending upon the nature of the request and applicable law. RedeApp will not unlawfully discriminate against any individual for exercising privacy rights. Privacy requests may be submitted by contacting privacy@redeapp.com, in writing at the address listed in Contact Information below, or through any online privacy request mechanism made available by RedeApp. RedeApp will respond to privacy requests within forty-five (45) days, or within such shorter period as required by applicable law and will notify you if additional time is required and the reason for the extension. RedeApp does not charge a fee for responding to privacy requests unless a request is manifestly unfounded or excessive, in which case RedeApp may charge a reasonable fee or decline to act to the extent permitted by applicable law.

F. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding use of your personal information. With respect to personal information RedeApp processes on behalf of its Customers through the platform, RedeApp processes that information only to provide the Services, on the Customer’s instructions and in accordance with the applicable customer agreement, and does not use it for its own commercial purposes. Where a customer agreement includes data processing terms establishing RedeApp’s role as a service provider or processor under applicable law, those terms govern that relationship. The applicability of state privacy statutes to tribal entities operating on reservation land is determined by tribal sovereignty and applicable federal law. If you are user of our RedeApp Services and you believe you may have additional rights under California law, you should contact your employer or other third-party organization to exercise these rights. Where RedeApp acts as a business with respect to your personal information, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), provides California residents the rights described in Privacy Rights and Requests above, together with the right to limit the use and disclosure of sensitive personal information to purposes necessary to provide the Services requested. The categories of personal information RedeApp collects, the sources of that information, the purposes for which it is used, and the categories of recipients to whom it is disclosed are described in Additional U.S. State Privacy Rights below. RedeApp does not sell or share personal information collected through the RedeApp platform or applications. Personal information collected through RedeApp’s marketing website may be “sold” or “shared,” as those terms are defined by the CPRA, through third-party advertising and visitor-identification technologies, and California residents may opt out as described in Your Rights and Choices. California residents under eighteen (18) years of age who are registered users of the RedeApp Services may request removal of content or information they have publicly posted by emailing privacy@redeapp.com. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. At this time, we do not engage in this type of disclosure.

G. Nevada Privacy Rights

Nevada residents have the right to opt-out of the sale of certain “covered information” collected by operators of websites or online services. We do not sell covered information, as “sale” is defined by Nevada law.

H. Additional U.S. State Privacy Rights

Residents of certain U.S. states may have additional rights under applicable privacy laws, including California, Colorado, Connecticut, Delaware, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and Washington, and under consumer health data laws including the Washington My Health My Data Act and Nevada Senate Bill 370, and other jurisdictions that enact similar legislation. The categories of personal information RedeApp collects are described in Information We Collect and Receive above, and include identifiers; contact information; commercial information; internet or network activity; device information; approximate geolocation information; professional or employment information; communications; user-generated content; authentication information; account information; health-related information, which RedeApp treats as sensitive personal information; inferences drawn from usage of the Services; and other information described in this Privacy Policy. RedeApp collects personal information from users; Customers; Administrators; integrated third-party systems; service providers; publicly available sources; devices used to access the Services; and the automated technologies described in this Privacy Policy. RedeApp processes personal information for the purposes described in How We Use Your Information above and may disclose personal information to the categories of recipients described in Third Party Information Collection and Sharing and Disclosure of Information above.

I. Sale, Sharing, and Sensitive Information

RedeApp does not sell or share personal information collected through the RedeApp platform or applications. Personal information collected through the RedeApp marketing website may be sold or shared, and processed for cross-context behavioral advertising, as those terms are defined under applicable state privacy laws, through third-party advertising and visitor-identification technologies, and individuals may opt out as described in Your Rights and Choices and Cookies and Similar Technologies. RedeApp does not knowingly sell or share the personal information of individuals under sixteen (16) years of age. Should RedeApp’s processing activities materially change, this Privacy Policy will be updated accordingly. Except with respect to health-related information, which is processed as described in Information We Collect and Receive above, where RedeApp processes sensitive personal information, such information is processed only as reasonably necessary to provide the Services, comply with legal obligations, protect security, fulfill contractual commitments, or otherwise as permitted by applicable law, and RedeApp does not use sensitive personal information to infer characteristics about individuals except as permitted by applicable law.

J. European Economic Area, United Kingdom, and Switzerland

Where RedeApp acts as a controller with respect to personal data of individuals located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, RedeApp processes that personal data on the following lawful bases under the EU General Data Protection Regulation (“GDPR”) and the UK GDPR: (a) performance of a contract, where processing is necessary to provide the RedeApp Services that you or your organization has requested; (b) legitimate interests, including improving the Services, preventing fraud, and ensuring network security, where those interests are not overridden by your data protection rights; and (c) consent, where you have provided consent for a specific processing activity, such as the use of non-essential cookies and similar technologies. Your rights of access, rectification, erasure, restriction, portability, objection, and withdrawal of consent, and the process for exercising them, are described in Privacy Rights and Requests above. You also have the right to lodge a complaint with your local supervisory authority. International transfers of personal data, and the safeguards applicable to them, are described in International Transfer below.

13. Security

We follow generally accepted security measures standards to protect information that is submitted to us, both during transmission and once we receive it, which includes encrypted storage practices, firewalls and user password protection. The security of user information extends to internal reviews of our information collection, processing, and storage processes. Each of our employees is aware of our security policies, and your information is only available to those employees and contractors who need it to perform their job functions and who are subject to contractual confidentiality obligations. RedeApp maintains administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of personal information, including against unauthorized access, use, disclosure, alteration, and destruction, and our security program is designed to reflect the sensitivity of the information we process, the nature of our Services, and applicable legal and contractual obligations. Depending on the Services, security measures may include, as appropriate, encryption of data in transit (including TLS); encryption of data at rest; logical access controls; role-based access management; multi-factor authentication for privileged accounts; network monitoring; intrusion detection; vulnerability management; security logging and monitoring; secure software development practices; employee confidentiality obligations; vendor security reviews; disaster recovery planning; business continuity planning; periodic security assessments; and incident response procedures.

Additional information regarding RedeApp’s security practices is available through our security documentation located at https://redeapp.com/security. Although RedeApp employs commercially reasonable safeguards, no method of transmitting or storing information is completely secure, and RedeApp cannot guarantee the absolute security of personal information. Users are responsible for maintaining the confidentiality of their account credentials and for promptly notifying RedeApp of any suspected unauthorized access or security incident involving their accounts.

Breach Notification. In the event of a security breach resulting in unauthorized access to or disclosure of personal information that is likely to result in a risk of harm to affected individuals, RedeApp will notify affected individuals and applicable regulatory authorities to the extent and in the manner required by applicable law. Where RedeApp processes personal information on behalf of a Customer, RedeApp will notify the applicable Customer without undue delay in accordance with the applicable customer agreement or Data Processing Addendum, and the Customer is responsible for notifying affected individuals and regulators where it acts as controller. Notification will be provided without unreasonable delay and consistent with applicable state, federal, and foreign breach notification requirements, and will include, to the extent known, the nature of the incident, the categories of information involved, the measures RedeApp is taking in response, and steps individuals may take to protect themselves.

14. Data Retention

A. Retention Periods

RedeApp retains personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, enforce agreements, maintain the security and integrity of the Services, and support legitimate business operations. Because RedeApp primarily provides business-to-business software, retention of most information processed through the Services is determined by the applicable customer agreement, the Customer’s configuration of the Services, and the Customer’s instructions rather than by a uniform period set by RedeApp. RedeApp does not apply a single retention period across all categories of information. Retention is instead determined by the following criteria: Account and profile information is retained for the duration of the applicable account and for a reasonable period after the account is deactivated or the Customer relationship ends. Communications and User Content are retained in accordance with the applicable customer agreement, the Customer’s configuration, the Customer’s instructions, and applicable legal requirements. Usage, log, and diagnostic information is retained for as long as reasonably necessary to operate, secure, monitor, and troubleshoot the Services, to investigate security events, and to satisfy legal and contractual obligations. Billing and transaction records are retained as necessary to satisfy tax, accounting, audit, and recordkeeping obligations. RedeApp honors signed Customer requests for permanent deletion of Customer data across in-scope systems. Where RedeApp determines that personal information is no longer required for any purpose described in this Privacy Policy, RedeApp securely deletes, de-identifies, or anonymizes it, subject to the backup and disaster recovery processes described below.

B. Factors Affecting Retention

Factors that may affect retention include the duration of the Customer’s subscription or relationship with RedeApp; the type of information collected; applicable legal, tax, accounting, or regulatory obligations; contractual commitments; the need to investigate or resolve disputes; security incident response and forensic requirements; backup and disaster recovery processes; and applicable statutes of limitation.

C. Customer-Controlled Retention

Where RedeApp processes personal information on behalf of a Customer, the Customer generally controls applicable retention periods through the Services or pursuant to the parties’ agreement. Following expiration or termination of a Customer’s subscription, RedeApp will retain, return, or securely delete personal information in accordance with the applicable customer agreement, Data Processing Addendum, applicable law, and RedeApp’s internal data retention policies. Certain information may remain in secure backups for a limited period before being automatically overwritten in accordance with RedeApp’s backup and disaster recovery procedures.

D. Extended Retention

RedeApp may retain personal information beyond normal retention periods where reasonably necessary to comply with legal obligations; preserve evidence; establish, exercise, or defend legal claims; investigate fraud or security incidents; enforce contractual rights; or comply with lawful governmental requests.

E. Retraction, Deactivation, and Deletion

Certain features of the Services allow Users or Administrators to retract or remove content. Retraction removes content from recipients’ inboxes and from view within the Services, but does not delete that content from RedeApp’s systems.

The Services are provided to Users by their employer or organization, and User Content submitted through the Services is Customer data. Customers may be subject to legal, regulatory, or contractual obligations requiring retention of business communications. For that reason, individual Users cannot delete Customer data from RedeApp’s systems. Users may deactivate their own account at any time from within the Services. Deactivation ends the User’s access to all RedeApp networks, and the Customer’s Administrator is notified. User Content previously submitted remains available to the Customer in accordance with the applicable customer agreement and the Customer’s own retention policies. Permanent deletion of Customer data from RedeApp’s systems is performed at the documented request of an authorized representative of the Customer.

F. Removal from a Customer Network

Where a Customer removes a User from its network, whether manually or through an automated directory or human resources integration, that User’s access to the Services ends. User Content previously submitted by the User remains available to the Customer in accordance with the applicable customer agreement and the Customer’s configuration of the Services.

15. International Transfer

A. Transfers Generally

RedeApp is headquartered in the United States, and personal information may be transferred to, stored, or processed in the United States or other jurisdictions in which RedeApp or its service providers operate. Your information may be transferred to, and maintained on, servers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to RedeApp, please be advised that we transfer personal information to the United States and process it there. Some service providers may process personal information outside the country where it was originally collected. Where required by applicable law, RedeApp implements appropriate safeguards governing international transfers of personal information, including, where applicable, Standard Contractual Clauses, the UK International Data Transfer Addendum, contractual data processing agreements, and other lawful transfer mechanisms recognized under applicable law. Additional information regarding international transfers is available in RedeApp’s Data Processing Addendum, where applicable. If your company or organization has agreements in place with RedeApp that apply to international relations and transfer and or location of specific data, those agreements shall govern in case of conflict with this Privacy Policy.

B. EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework

RedeApp complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. RedeApp has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. RedeApp has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

RedeApp’s self-certification covers personal data other than human resources data. RedeApp has no establishment and no personnel in the European Economic Area, the United Kingdom, or Switzerland, and does not receive human resources data, as that term is used in the DPF program, in reliance on the frameworks.

Onward transfer. RedeApp is responsible for the processing of personal data it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. RedeApp complies with the DPF Principles for all onward transfers of personal data from the European Union, the United Kingdom, and Switzerland, including the onward transfer liability provisions. In the context of an onward transfer, RedeApp remains liable under the DPF Principles if its agent processes such personal data in a manner inconsistent with the Principles, unless RedeApp proves that it is not responsible for the event giving rise to the damage.

Dispute resolution. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, RedeApp commits to resolve complaints about our collection or use of your personal data transferred in reliance on those frameworks. Individuals in the European Union, the United Kingdom, or Switzerland with inquiries or complaints regarding our handling of personal data received in reliance on those frameworks should first contact RedeApp at privacy@redeapp.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, RedeApp commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on those frameworks.

Federal Trade Commission. RedeApp’s commitments under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Binding arbitration. Under certain conditions, more fully described on the Data Privacy Framework website at https://www.dataprivacyframework.gov/, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

RedeApp’s full Data Privacy Framework Notice is available at https://redeapp.com/data-privacy-framework.

16. Children

RedeApp Services are intended for use by businesses, organizations, and their authorized users, and are not directed to children under thirteen (13). Accounts are provisioned by Customers for members of their workforce. RedeApp does not collect date of birth directly from Users and does not verify the age of any User. Where a Customer provides date of birth as part of an employee data file, RedeApp processes that information at the Customer’s direction to support the Customer’s configuration of the Services. Customers are responsible for determining which individuals are eligible to receive accounts and for obtaining any consents required under applicable law with respect to minor employees. If RedeApp becomes aware that it has collected personal information from a child under thirteen (13) other than as directed by a Customer, RedeApp will delete that information and restrict the account. RedeApp complies with the Children’s Online Privacy Protection Act with respect to children under thirteen (13).

17. Changes to this Privacy Policy

RedeApp may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations, technologies, products or Services. We will post any changes we may make to our Privacy Policy on this page. If the changes materially alter how we use or treat your information we will notify you by email to the primary email address specified in your account (if you have an account with us) and/or through a notice on the website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date email address for you and for periodically visiting our website and this page to check for any changes. Notice of material changes may also be provided through the Services or by other reasonable methods of communication. Continued use of the Services following the effective date of an updated Privacy Policy constitutes acknowledgment of the revised Privacy Policy to the extent permitted by applicable law. Where applicable law requires your affirmative consent to material changes, RedeApp will obtain that consent as required by applicable law.

18. Contact Information

If you have questions regarding this Privacy Policy or RedeApp’s privacy practices, or if you wish to exercise any applicable privacy rights, please contact:

Red e App, Inc.
828 E. Market St.
Louisville, KY 40206

Email: privacy@redeapp.com