Privacy Policy

Last updated Aug 27, 2019

(“Catalyst”) and/or Revel Digital Worldwide Operations (“RDWO”, “Revel Digital”, “we”, “us”, or “our”) is focused on making the RDWO service the safest and best possible experience for you and your end-users (“you”, “your”). We have great respect for people’s personal privacy, and we consider this a matter of great importance. In order to provide you with a useful service when you are purchasing our products or using our services; we need some data from you in order to do so; otherwise we cannot provide you with a useful product and service. Our commitment to you is that we will use our best efforts to ensure any information submitted to, or gathered by us; remains private, and is only used for the purposes set forth in this policy.

This page states the RDWO Privacy Policy (herein the “Policy”) and sets forth the collection, use, and disclosure practices that apply to the RDWO Website, RDWO Software, RDWO Services, and RDWO Products (herein “Services”). The Policy also incorporates by reference the RDWO Terms of Service for the RDWO Experience, which apply to this Policy. By purchasing or using the Experience; you explicitly accept, without limitation or qualification; the collection, use, and disclosure of personal information provided by you in the manner described in this Policy. Please read the Policy carefully as it affects your rights and liabilities. If you disagree with the way we collect and process personal information, please do not use the RDWO Experience.


What Information Do We Collect?

Information You Submit

When you request information, subscribe to or order a product or service, register as a user, respond to an online survey, or otherwise actively send us data; we may collect data including, but not limited to; your name, email address(es), mailing address(es), telephone number(s), and information related to the business you represent. If the product or service provided is something we charge for, we will also collect payment information; such as credit card numbers and related verification information, phone number, email address, and billing / shipping addresses; in order to process the order. In all of the above cases, you will know exactly what data we collect through the Site, because you actively submit it to us.

Information We Gather

As part of the standard operation of the Site, we may collect information from your computer or device; including but not limited to your browser type, device type, operating system, IP address, and the domain name from which you accessed the Site. Additionally, we may collect behavioral information about your use of the Site; this includes but is not limited to; the date and time you visit the Site, actions taken while accessing information on the Site, which areas or pages of the Site you visit or view, the amount of time you spend viewing the Site, the number of times you return to the Site, and other such analytics data. We may also collect similar data regarding your usage of our Services. We also may acquire personal information from third parties who provide it to us.

Information Obtained Through Other Sources

Due to the nature of our Services, information about you may be collected by a RDWO customer or other affiliated third party; and this information may be stored, transmitted, processed, or otherwise put into some form of use; using some or all elements of RDWO’s Services or resources (such as servers and databases etc.). The collection and usage of such information occurs outside the control of RDWO, and therefore we are not responsible for any privacy issues caused by a RDWO customer or otherwise affiliated third party. The third party in question is responsible for upholding and enforcing their own Privacy Policies, License Agreements, and Terms of Service. Please review our Terms of Use for more information.


How Do We Use the Information?

For the purposes of this policy, the terms “using” and “processing” of information includes; the use of cookies, analyzing information through various methods, other means of storage on a computer or mobile device, and also the collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information; within our organization or among our subsidiaries within the European Union, the United States, or internationally.

Personal Information

We use Personal Information for only the following purposes: (1) to operate the Services, (2) account verification, (3) to fulfill product and services requests, (4) to improve and optimize the Services, (5) to personalize your experience, (6) responding to inquiries or providing support, (7) to provide software updates and product announcements, (8) to better understand your needs and interests, and (9) to provide you with further personalized information and offers from us that we believe you may find useful or interesting, based on your behavioral and declarative data, such as targeted advertising or promotional campaigns in RDWO and third-party channels (which is known as profiling).

Non-Personally Identifiable Information

We may use Non-Personally Identifiable Information for the following purposes: (1) to analyze trends and usage of resources through aggregated data, (2) to improve the features and functionality of our Services, (3) to better understand your needs and interests, and (4) to better understand the needs and interests of End-Users. We may also share Non-Personally Identifiable Information from End-Users with our RDWO Account Holders, to allow them to provide more value to end-users, or to provide more insight into end-users. In this context, any information shared with Account Holders; will not contain or be linked to your Personal Information; unless you have given us your explicit consent or the end-user has given us their explicit consent. For example, a RDWO Account Holder may want to better understand how to create a compelling and non-intrusive experience for end-users, and RDWO may provide aggregated information to show examples of practices that worked well, and practices that did not work well.

Cookies and Other Technologies

A cookie is a small text file that may be stored on the hard drive of your computer or device when you access the Site. We may use cookies and/or other storage on your device to help us collect, maintain, and use this information, for the following purposes: (1) personalize your experience and provide you with customized content, (2) monitor Site and Account usage to better understand how you interact with our Services, (3) remember you when you return to the Site, and (4) conduct research to improve our content and services. You may refuse to accept cookies, but by doing so you may not be able to use certain features on the Site, or take full advantage of all of our offerings. All web browsers offer you some form of ability to manage your cookie preferences. We also use web beacons (invisible images often referred to as pixel tags or clear GIFs) on our sites in order to recognize users, assess traffic patterns, identify preferred content and measure site engagement. We also include web beacons in our e-mail messages, including newsletters, in order to count how many e-mail messages have been opened. We may also use a third party analytics partner, who may employ some form of software technology to help us better manage content on our Site; by informing us about what content is effective. The information gathered by third party analytics software is not tied to Personally Identifiable Information; however the use of cookies and other technologies by our partners and service providers is not covered by our privacy statement. We do not have access or control over these third party cookies and technologies. Our Site also includes social media features, such as the Facebook “Like” button and Twitter “Tweet” button. These features may collect your IP address and page visits; and may set a cookie to enable their feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

When Do We Share or Disclose Information? We may disclose or share information collected from you and about you; to the following entities; for the following purposes: (1) to our service providers and suppliers, if such disclosure enables any of them to perform a business, professional, or technical support function for us, for example to process payments, (2) as necessary if we believe that there has been a policy violation such as those published on our site, or some violation of terms you signed, or some other violation of our rights or the rights of any third party, (3) to respond to judicial process and provide information to law enforcement agencies, or in connection with an investigation on matters related to public safety, as permitted by or otherwise required by law, and (4) otherwise with your consent. Additionally in the event of a merger, acquisition, reorganization, or sale of our company or our assets, or in the event of our bankruptcy; your personal information may be one of the transferred or acquired assets. We may also share your personal information where you have granted us permission to do so, and we reserve the right to use and disclose any information collected via the Site that is not in a Personally Identifiable form.

How Can I Update or Delete My Personal Information?

You may review, update, correct, or delete any Personal Information in your RDWO Account by contacting us, or by making the appropriate modifications in your Account profile or preferences. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your Account and/or remove your records from our systems, please contact us and we will delete your account and your Personal Information within 30 days if we do not have any legal obligation to retain the record.


Is My Information Secure?

Security is of paramount importance to us, and we work hard to ensure that our Site and Services are as secure as is possible. We have taken certain physical, electronic, contractual, and managerial steps to safeguard and secure the information we collect from Site visitors and Service users. However no method of transmission over the Internet, or method of electronic storage, is ever 100% secure; therefore while we endeavor to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you register on our Site or use our Services, it is your responsibility to protect the security of your Account, and any end-users you are providing services to through our Services and your Account.


International Transfer

Your information may be transferred to, maintained on, and processed; on computers located outside of your country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We have taken reasonable measure to ensure compliance with the privacy laws of the United States of America and the European Union, and will take further reasonable measures to maintain and/or improve compliance in the future. The protections given to you by this Privacy Policy still apply. Your submission of any such information discussed in this policy, represents your agreement to that transfer.


Links, and Third Party Sites and Services

The Site may contain links to Third Party Websites, and some Third Parties may use our Services to provide services to end-users. Third Parties may have privacy policies that differ from our own, and we are not responsible for the activities and practices that take place on these sites; or any services provided through our Services. We therefore encourage you to review the privacy policy posted on the Third Party Website; should you access them through the Site, or through our Services. The fact that we may link to or incorporate a third party’s services, functionality, or website; or present some type of advertisement; is not an endorsement, authorization, or representation of our affiliation with that third party; nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over Third Party Websites, or any third party services provided through our Services; including their use of personal information. Our Privacy Policy only applies to our Site and Services, and we are not responsible for the privacy practices or content of other websites, or third party services provided through our Services.


General

Do Not Track

We do not currently use a mechanism to act upon “Do Not Track” instructions. We are however investigating such mechanisms.

Information Retention

We will retain your information for as long as your Account is active, or as is needed to provide you with our Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Additionally we will delete information after it is no longer useful for providing our Services.

Children’s Information

The Site and our Services are not directed to children under the age of 13, nor do we knowingly collect any personal information from them.

Policy Agreement

By using any part of the Site or our Services, you agree to the current Privacy Policy and Terms of Service to which this Privacy Policy is incorporated.

Changes to This Policy

We reserve the right to make change this privacy policy from time to time at our sole discretion. When we do, we will post the change(s) on our website.

User Rights

You may request, and we will provide you with, information about whether we hold any of your personal information. You may request access to, or correction or deletion of your personal information, by contacting us at privacy@reveldigital.com. We will respond to your request within a reasonable timeframe.


Additional Notice for Certain European Residents

The following Additional Notice applies only to residents of the European Union, the European Economic Area and Switzerland who visit the Site.

Personal Data and Processing

For the purposes of this Additional Notice:

“Personal Data”

means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.

“Processing”

means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Purposes and Legal Bases for Processing Personal Data

RDWO processes data for the purposes as set forth in this Privacy Policy, including providing the Site and other services to users as explained in the How We May Use Your Information and How Your Information Is Shared sections.

Our lawful bases for the Processing of Personal Data are: (i) consent and/or (ii) any other applicable lawful bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the users of the Site, preventing fraud, ensuring information and network security, direct marketing and complying with industry practices.

Compelled Disclosures

RDWO may be required to disclose Personal Data in response to lawful requests by public authorities, including disclosures necessary to meet national security or law enforcement requirements, or pursuant to judicial orders.

Additional Rights for European Residents

As a resident of the EU or a country following substantially-similar legislation regarding the protection of Personal Data, you may have one or more of the following additional rights available to you:

Access

To request a copy of the Personal Data we have collected about you by contacting us at privacy@reveldigital.com.

Rectification & Erasure

To request that we correct or delete any Personal Data about you that is incomplete, incorrect, unnecessary or outdated.

Objection

To object, at any time, to Personal Data about you being Processed for direct marketing purposes.

Restriction of Processing

To request restriction of Processing of Personal Data about you for certain reasons, such as, if you consider Personal Data about you collected by us to be inaccurate or if you have objected to the Processing in accordance with your rights under Data Protection Laws and Regulations.

Data Portability

To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.

Right to Withdraw Consent

If Personal Data about you is Processed solely based on your consent and not for any other lawful basis, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for RDWO Services.

Right to Lodge a Complaint with a DPA

If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).

To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at privacy@reveldigital.com. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify your identity before processing your request.


Privacy Shield Notice

The following Additional Notice applies only to residents of the European Union, the European Economic Area and Switzerland who visit the Site.

EU-U.S. and Swiss-U.S. Privacy Shield Notice.

We have certified our compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (collectively, the “Privacy Shield Framework”) with respect to the Personal Data of users of the Site who are residents of the European Union (“EU”), European Economic Area (“EEA”) and Switzerland that we receive and process through the Site. We certify that we adhere to the Privacy Shield Framework principles of notice, choice, onward transfer, security, data integrity, access and enforcement (the “Privacy Shield Principles”) for Personal Data of users of the Site in the countries participating in the Privacy Shield Framework. We are responsible for the processing of personal data we receive under the Privacy Shield Framework and subsequently transfer to a third party agent, and may be liable for onward transfers in violation of the Privacy Shield Principles. Our certification is available here. We may also process Personal Data relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Questions and Complaints

If you are a resident of a country participating in the Privacy Shield Framework, you may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact listed below. We will work with you to resolve your issue.

If you have not received timely response to your concern relating to data processed under the Privacy Shield Framework, or we have not addressed your concern satisfactorily, you may contact our U.S.-based dispute resolution provider, at no cost to you, at https://www.bbb.org/EU-privacy-shield/for-eu-consumers . If neither RDWO nor our independent dispute resolution provider resolves your complaint, you may have the right to invoke binding arbitration through the Privacy Shield panel. However, prior to initiating such arbitration, a resident of a country participating in the Privacy Shield Framework must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent dispute resolution provider; and (3) contact the U.S. Department of Commerce (either directly or through a European DPA) and afford the Department of Commerce time to attempt to resolve the issue. If a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield Framework, the arbitrator(s) may impose only individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

U.S. Federal Trade Commission Enforcement

RDWO’s commitments under the Privacy Shield Framework are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Privacy Shield and Data Protection Contact

Your Privacy Shield and Data Protection Contact for the personal data that we process in connection with the Site is:

Attn: Chief Privacy Officer
Revel Digital Worldwide Operations
300 NP Ave. STE 203
Fargo, ND 58102
Phone: +1-855-738-3534
privacy@reveldigital.com

Please include sufficient information so we can understand and respond to your specific question.


How to Contact Us

If you have any questions regarding this Privacy Policy, please contact us by email at privacy@reveldigital.com, or call +1-855-738-3534, or write to:

Attn: Privacy Team
Revel Digital Worldwide Operations
300 NP Ave. STE 203
Fargo, ND 58102

Please be sure to include sufficient information so we can understand and respond to your specific question or request.