Privacy Policy

This privacy notice describes your privacy rights regarding our collection, use, disclosure, retention, and protection of your personal information.

Effective Date

This Notice was updated on January 8, 2018.

Contents & Summary

		Scope and Consent This privacy notice describes your privacy rights regarding our collection, use, disclosure, retention, and protection of your personal information. It applies to any Radial Sites (defined below) where this notice appears in the footer, regardless of how you access or use them, including mobile devices. You should read it to learn how Radial will process and protect your data. By using this site or any related sites (collectively, “Sites”) where this Privacy Notice is displayed or referenced, you expressly consent to the terms of this Privacy Notice.
		Privacy Shield Certification Radial has certified that it adheres to the EU-U.S. Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
		Collection We collect different types of information on the Sites in order to provide you with the use of and access to our Sites, and to help us personalize and improve your experience on the Sites. This includes information we collect automatically (such as device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, referral URL, ad data, IP address, standard web log information, and anonymous information collected through our use cookies and web beacons) and information you give us (such as information you enter on our Sites or you provide to us in context of using our Sites).
		Use and Retention We use the personal information we collect to: operate, improve and personalize our Sites and services, to contact you about our services, and to customize our advertising and marketing. We retain your personal information only as long as it is necessary and relevant for our operations.
		Choice You have a choice about how we use your personal information to communicate with you, send you marketing information, and provide you with customized and relevant advertising. Access If you have provided us with your personal information and wish to update, correct, or delete it, you have the ability to contact us as indicated below. We will respond to any access requests within a reasonable timeframe. If your personal information was provided to us by a Radial client and you wish to update, correct or delete it, please contact that company directly.
		Disclosure There are times when we disclose your personal information to members of the Radial corporate family or other third parties. We do not disclose your personal information to unaffiliated third parties for their marketing and advertising purposes without your explicit consent.
		Security We store and process your personal information on our computers in the US and elsewhere in the world, where we use reasonable measures in an attempt to protect your information, such as using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration.
		Important Information This section describes some additional important information related to your use of our Sites. Please review it for more details.
		Questions or Complaints Questions regarding this Privacy Notice should be directed to Radial by email to privacy@radial.com or by regular mail to the attention of: Privacy Manager, Radial, 935 First Avenue, King of Prussia, PA 19406.

Scope and Consent

This privacy notice describes your privacy rights regarding our collection, use, disclosure, retention, and protection of your personal information. It also describes your choices regarding use, access and correction of your personal information. It applies to any Radial Site where this notice appears in the footer, and to any Radial application, service, or tool where this notice is referenced, regardless of how you access or use them, including mobile devices. You should read it to learn how Radial will process and protect your data.

By using the Sites where this Privacy Notice is displayed or referenced, you expressly consent to the terms of this Privacy Notice.

If all or part of Radial is sold, merged, or otherwise transferred to another entity, the information gathered by the transferred entity may be transferred as part of that transaction.

Personal Information

Throughout this Privacy Notice, we use the terms “personal information” or “personal data” to describe information that identifies a specific person, such as full name, email address or mailing address. We do not consider personal information to include: business contact information, business information publicly available on the internet or other public sources, information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person, or information that merely identifies a computer or browser, or an ID number assigned to an anonymous person.

Changes to This Notice

We may amend this Privacy Notice at any time by posting the amended terms on this Site. Any such amendment shall take effect when such amendment is posted on the Site. If we make any material amendments, we will notify you by email (sent to the email address you provided) or by means of a notice on this Site prior to the amendment taking effect.

Privacy Shield Certification

Radial, including members of the Radial corporate family, such as Radial South, L.P., participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework. Radial is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]

Radial is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Radial complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Radial is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Radial may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Collection

Categories of Individual Data Subjects

In general, Radial may obtain EU Personal Data in the United States about several different types of individuals, including consumers, Clients (defined below), suppliers and other business partners. Radial's practices with respect to each of these types of individual data subjects are described below.

Consumers

Radial provides a wide variety of services and solutions to its business clients (each, a "Client") that facilitate services for their customers ("Consumers"). In these cases, personal data collected from Consumers is owned by the applicable Client, and Radial processes this data on the Client's behalf. There may be limited instances in which Radial owns and processes personal data collected from Consumers on its own behalf, rather than on behalf of a Client. In all instances, Radial will obtain access to EU Personal Data about Consumers in the course of operating websites, processing payments, fulfilling orders, implementing marketing campaigns and providing customer care and other related services. Such data may include, name, billing address, shipping address, email address, telephone number, credit card or other payment information, and other information, depending on the particular Client, website or other application at issue. In all instances, Radial will not share, sell, rent, or trade with third parties for promotional purposes any personal data processed by Radial, unless Radial is directed to do so by a Client who owns such personal data.

Clients, Suppliers and Other Business Partners

Radial may obtain various types of EU Personal Data about employees and agents of its Clients, suppliers and other business partners. Such data may include contact information (e.g. names, addresses, telephone and fax numbers, and email addresses); user IDs and passwords; information collected through Internet-based and ecommerce activities; and other transaction-related data.

Radial may use these types of EU Personal Data for business purposes, including to establish and maintain Client, supplier and other business relationships; to deliver or provide products or services; to provide access to Internet-based applications; to perform accounting functions; and to conduct other activities as necessary or appropriate in connection with the establishment, servicing and development of the business relationship.

Why We Collect Information

We (including all members of our corporate family) may collect and use the information collected at our Sites for any internal purpose, and we may provide that information to our business partners and vendors to be used by them in connection with such purposes. For example, we may use this data to monitor our Sites and to collect aggregate data for marketing purposes and for other future uses, or to determine the most appropriate information to send to those who request it.

You may choose voluntarily to give us personally identifiable information, such as your name, address, phone number, email address, or other information about yourself. In addition, we may collect information automatically as you navigate our sites. This information may include (but may not be limited to): location data, IP address, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our sites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, clickstream data, device data such as mobile identifiers, carrier network information, the mobile website or mobile app used, and cookie or pixel tag data.

Certain forms on our sites may also request contact and profile information, such as user name, email address, website, phone number, or company information. Completion of these forms is entirely voluntary but may be required in order to request certain services from Radial. Resume submissions on our Sites are used to screen candidates and contact them for interviews.

Radial may also use our sites to periodically survey our clients for purposes of improving the quality of our service and customer satisfaction. Client participation is completely voluntary, and any information we collect from you as part of our surveys will be treated with the same respect as any other information gathered in accordance with this Notice.

How We Collect It

Our Sites use web beacons and other technologies to collect information when you access our websites, and we may store that information in “cookies”.

We only obtain personally identifying information if it is supplied voluntarily. If you have chosen to receive marketing messages from us about our products and services, we may use information from our log files, cookies, or web beacons to help us make those communications more useful or interesting to you. We may periodically track the open-rates and click behavior of our emails and other messages and advertisements to help us identify which portions of our advertisements are most popular and effective with our customers.

How We Use Cookies and Other Technologies

When you access our sites, we and our affiliates, business partners and vendors may place small data files on your computer or other device. We use these data files, commonly known as “Cookies” to help us identify you as a site visitor or Client, customize our content and enhance your site experience. These third parties may also use a technology called “Tags” or “Web Beacons”. Similar in function to Cookies, Web Beacons allow us to understand the movements of visitors to our Sites. The tracking technologies on our Sites do not collect personal information. We use this information to analyze trends, to administer our Sites, to track users' movements around the Sites, and to gather demographic information about our user base as a whole. Radial does not provide personal information through the use of web beacons and cookies to these parties.

You should note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first party or third party cookies or to indicate when a third party cookie is being sent. However, disabling or limiting cookies may cause certain features of this site to not function properly. Check your browser’s “Help” files or other similar resources to learn more about handling cookies on your browser.

Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you may include address information about you from third party sources, such as the U.S. Postal Service, to verify your address. This information is used for payment processing, fraud prevention and fulfillment services.

Do Not Track

California law requires us to state how we respond to Do Not Track (DNT) signals. Because there is currently no industry or legal standard for recognizing or honoring DNT, we do not currently respond to DNT signals. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Use and Retention

Use

We use the information we gather to help us improve our services to offer the best user experience possible, to communicate with our Clients, or for other internal purposes and to generally operate the Sites. You agree that we may use your personal information as follows:

• To deliver information specific to your interests
• To create a profile detailing your service preferences so that we can best serve you
• To save you from having to re-enter your password each time you visit our site
• To better analyze our site traffic patterns so that we can bolster our Web offering
• To respond to your questions or to provide you with the information you have requested

Any non-personally identifiable material, information, suggestions, ideas, concepts, know-how, techniques, questions, comments, or other communication you transmit or post to our Sites in any manner will be considered non-confidential and non-proprietary "User Communications." Radial and each of our affiliates and/or their designees may use any or all User Communications for any purpose whatsoever, including, without limitation, reproduction, transmission, disclosure, publication, broadcast, development, manufacturing and/or marketing in any manner whatsoever for any or all commercial or non-commercial purposes.

Retention

We retain your personal information only as long as it is necessary and relevant for our operations.

In addition, we retain personal information from closed accounts to: comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted by law.

Choice

You have a choice about how we use your personal information to communicate with you, send you marketing information, and provide you with customized and relevant advertising.

Advertising

We may partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if located in the European Union, click here. Please note you will continue to receive generic ads.

Marketing

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services or content.

You may opt-out of the marketing messages we send at any time by utilizing the unsubscribe information provided in such message or by contacting us at privacy@radial.com.

If you choose to unsubscribe from emails, please click unsubscribe in the applicable email message. Rarely, we may need to contact you regarding non-promotional purposes. You cannot opt out of these operational emails.

Access to Information

Upon request Radial will provide you with information about whether we hold, as a data controller, any of your personal information. You may access, correct, or request deletion of your personal information by emailing us at privacy@radial.com. We will respond to your request within a reasonable timeframe.

Radial acknowledges that you have the right to access your personal information. Radial has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Radial’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that uses our service, please contact the Client directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients or vendors, as applicable.

Disclosure

As stated above, we and our affiliates may collect and use the information collected at our Sites for any internal purpose and provide that information to our business partners and vendors to be used by them for such related purposes. We may also disclose personal information to respond to legal requirements, enforce our policies, respond to claims that user or Client content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with this Privacy Notice and applicable laws and regulations. As stated above, we never disclose your personal information to unaffiliated third parties for their marketing purposes without your explicit consent.

We may also share your personal information with:

• Members of the Radial corporate family to provide joint content and services (such as registration, transactions, and customer support), to share contact information and basic corporate information with sister companies for the purpose of marketing other products and services that may be relevant to your business, to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches, and to guide decisions about products, services, and communications.
• Service providers under contract who help with parts of our business operations such as marketing and technology services. Our contracts dictate that these service providers only use information in connection with the services they perform for us and not for their own benefit;
• Law enforcement, government officials, or other third parties when we
  • Are compelled to do so by a subpoena, court order or similar legal procedure, and
  • Believe the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreements.
• Companies that we plan to merge with or be acquired by.
• Any other third party with your prior consent.

If you use a bulletin board, chat room, blog, or other public forum function on our Sites, you should be aware that any personal information you submit there may be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.

Security

We store and process your personal information on our computers in the US and elsewhere in the world where our facilities are located. We protect your information using reasonable technical and administrative security measures in an effort to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. You acknowledge and agree that our security measures are not a guarantee of security and that we are not responsible for loss or misuse of your personal information.

Important Information

Children’s Privacy

The Radial Sites are general audience websites and are not intended for children under the age of 13. We do not knowingly collect personal information via our Sites from users in this age group. If we discover we have inadvertently gathered any personal information from this age group, appropriate steps will be taken to delete it.

Third Parties

This Privacy statement only applies to information received or collected by Radial Sites or information received and processed by Radial (and all members of its corporate family) from its Clients or its Clients’ third-party vendors. Our Sites do not control the privacy practices of third parties. Consumers who click on a link or advertisement, visit a third-party site, or interact with third-party content are subject to the privacy policies of those third parties, where applicable.

Questions or Complaints

Questions regarding this Privacy Notice should be directed to Radial by email to privacy@radial.com or by regular mail to the attention of:

Privacy Manager
Radial
935 First Avenue
King of Prussia, PA 19406