Last updated: July 6, 2020
The privacy of your data is a important to us. In this policy, we lay out what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data.
This policy applies to all products built and maintained by Radial Development Group, LLC including all Radial web properties and The Armory Co-working. What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you engage with Radial, we typically ask for identifying information such as your name, email address, phone number and company information, so we can interact with you respectfully. We’ll never sell your personal info to third parties .We won’t use your name or company in marketing statements without your permission.
When you pay for a Radial service, we may ask for your credit card and billing address, so we can charge you for service, calculate taxes due, and/or send you invoices. Your credit card is passed directly to our payment processor and doesn’t go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States to detect fraudulent credit card transactions, and to print on your invoices.
Web analytics data — described further in the Website Interactions section — are also tied to IP addresses, and/or your user profile, to assist with troubleshooting cases.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, and which website referred you for statistical purposes like conversion rates or to test new features. We sometimes track specific link clicks to help inform some decisions. These web analytics data are tied to your IP address and user account if applicable.
We use, on a limited basis, third-party web analytics software. This is currently limited to Google services, in the context of Google Analytics services and for purposes of assessing out marketing efforts for effectiveness.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org. At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write Radial with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future. We also store any information you provide us in the context of surveys, or other feedback requests.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our team; we will do our best to use those terms in addressing you.
We do not collect any biometric data. If you are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
- To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties.
- To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
- When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to share data, we have to comply. Otherwise, we will reject requests from local and federal law enforcement if they seek data. Unless we’re legally prevented from it, we’ll always inform you when such requests are made. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
If Radial Development Group, LLC is acquired by or merged with another company, we will make every effort to notify you.
Location of Site and Data
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Your Rights With Respect to Your Information
At Radial, we apply the same data rights to all customers. Currently some of the most forward-looking regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Radial recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten.” This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Radial services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information.
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org or at Radial Development Group, LLC, 601 Cleveland Avenue, PO BOX 7131, Loveland, Colorado 80537, USA. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
We use best efforts to ensure that all data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database, but we go to great lengths to secure your data at rest.
EU-US and Swiss-US Privacy Shield policy
The GDPR requires that data transfer out of the EU must only happen to countries deemed as having adequate data protection laws. The United States generally doesn’t meet that requirement. Privacy Shield is an agreement between certain European jurisdictions and the United States that allows for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary.
We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States
Radial is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.
The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:
- Individuals have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Individuals also have the right to request erasure of personal information that has been processed in violation of the principles. Individuals wishing to exercise these rights may do so by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at email@example.com or at Radial Development Group, LLC, 601 Cleveland Avenue, PO BOX 7131, Loveland, Colorado 80537, USA.
- We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
- We do not sell personal data nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-out or opt-in choice as appropriate.
- We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
We commit to resolving all complaints
Radial (the company) has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/bbb-privacy-shield/eu-dispute-resolution for more information and to file a complaint. This service is provided at no cost to you. Please do not submit GDPR complaints to BBB EU Privacy Shield.
If your Privacy Shield complaint cannot be resolved through these described channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please view the Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices.