Privacy Policy
[Last Modified: July 10, 2023]
RedTLV Ltd. ("Company" or "we" or "our" or "us") is committed to upholding the principles outlined in this Privacy Policy ("Privacy Policy") with regard to your utilization of the offering, encompassing the Company's search product presently referred to as "BudgetBuddy" ("Offer"), as well as the services we furnish therein, as explicitly defined within our Terms of Service ("Terms"). We hold profound respect for the privacy of our users, and we have meticulously crafted this Privacy Policy to provide you with a transparent comprehension of our data collection and privacy practices. We strongly urge you to carefully peruse this Privacy Policy before proceeding to download, access, or engage with our services. It's important to note that this Privacy Policy is an integral component of our overarching Terms. The definitions established herein retain the same meanings ascribed to them within the aforementioned Terms.
This Privacy Policy explains what information we may collect from our users, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below) under the following legislation:
(i) The EU General Data Protection Regulation ("GDPR"), which shall apply to you in the event you are a resident of the European Economic Area ("EEA"); and
(ii) The California Consumer Privacy Act of 2018 ("CCPA") which shall apply to you in the event you are a "California resident", as defined under the CCPA.
If you have any questions about this Privacy Policy, please contact us at: info@redtlv.com
We do not use the Services to knowingly collect data from and/or market the Offer to "Children" as defined under any applicable law and specifically under the age of 16. In the event that we become aware that a child has shared any information, we will discard such information. If you become aware that children have shared any information with us, please contact us at info@redtlv.com. If you are under 18, please be sure to read this Privacy Policy with your parents or legal guardians.
Some of the web search services provided herein are provided by CodeFuel and powered by CodeFuel's search partners. For information on the web search services data collection, please visit http://www.codefuel.com/legal/end_user_privacy_policy, and the search provider's privacy policy, as applicable, both as updated from time to time and at any successor locations
THE INFORMATION WE COLLECT AND PURPOSE OF USE
We collect non-identifiable aggregated information ( "Non-Personal Data") about your device and your use of Services. In addition, we collect data that identifies a user or may identify a user, which is classified as "Personal Data" under applicable law. All, as detailed below.
EU General Data Protection Regulation ("GDPR") & Lawful Basis for Data Processing
Depending on the nature of your interaction with the Offer, our lawful basis for collection of Personal Data, as required under the GDPR, is as follows:
(i) We process certain Online Identifiers (as described below) during your download and use of the Service and for functionality and operational purposes, which we have a legitimate interest in processing;
(ii) We and our third party partners may use cookies for advertising purposes, which, subject to applicable law requirements, we will request your consent for us to do so; and
(iii) We may process information provided by you voluntarily - meaning, if and when you choose to provide us with information such as through contact us communications in order to perform our contract with you.
The types of data that we collect as well as the purpose for processing such data are specified below:
DATA WE COLLECT
1. Technical Data and Online Identifiers:
If you use our offer Services, we will collect your IP addresses.
In addition, we will collect technical data transmitted from your device such as, your aggregated use of the Service, statistics, type of browser, operating system type, language and the time and date you access and use the Service, website which you lead you to the Offer, approximate geographical location and Internet Service Provider (ISP)
Purpose of collection and use-
Collection of the IP address is necessary for operating and providing the Service, to further improve, refine, customize and develop those Services and Offer, as well as to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments.
Note that, in some jurisdictions Online Identifiers, might be considered as Non-Personal Data, and we treat such data in compliance with applicable laws.
2. Contact Details:
If you contact us for support and voluntarily provide us with your contact information, including your name and email address.
Purpose of collection and use-
We will process your contact details and contact history with us only in order to respond to you, provide you with support, assist you or provide you with any other service that you may request.
We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services).
California Consumer Privacy Act 2018 ("CCPA") & Categories of Personal Information Collected and Shared
Under the CCPA Personal Information does not include: Publicly available information from government records; De identified or aggregated consumer information.
As required under the CCPA , please see below a table specifying the categories of Personal Information we collect:
Category
A. Identifiers.
Examples
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Collected- yes
Category
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Collected- yes
Category
C. Protected classification characteristics under California or federal law.
Examples
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected- no
Category
D. Commercial information.
Examples
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected-no
Category
E. Biometric information.
Examples
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected- no
Category
F. Internet or other similar network activity.
Examples
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected- no
Category
G. Geolocation data.
Examples
Physical location or movements.
Collected- no
Category
H. Sensory data.
Examples
Audio, electronic, visual, thermal, olfactory, or similar information.
Collected- no
Category
I. Professional or employment-related information.
Examples
Current or past job history or performance evaluations.
Collected- no
Category
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected- no
Category
K. Inferences drawn from other personal information.
Examples
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected- no
Disclosures of Personal Information for a business purpose:
In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose: (A) Identifiers;
We disclose your Personal Information for a business purpose to the following categories of third parties: service providers & data aggregators (e.g. for analytics purposes), business partners (for fraud detection and payment calculation, as well as feed providers).
Sale of Personal Information
In the preceding twelve (12) months, Company has not sold Personal Information.
HOW WE COLLECT DATA
Depending on the nature of your interaction with the Services and Offer, the above detailed data is collected as follows:
- In the event you voluntarily choose to provide us with information, e.g., when you contact us.
- In an automated manner, including the utilization of cookies (elaborated upon below) and analogous tracking mechanisms.
- We will ask for your consent to collect Personal Information and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.
SHARING DATA WITH THIRD PARTIES
We do not share your Personal Data with any third parties. However, we may disclose such information if we have a good faith belief that the disclosure is reasonably necessary in order to: (i) comply with applicable law, regulation or governmental request and collaborate with law enforcement; (ii) enforce our policies and agreements, and establish or exercise our rights to defend against legal claims; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) prevent harm to the rights, property or safety of us, our users, yourself or any third party; (and (v) enforce intellectual property or other legal rights.
We will additionally disclose Online Identifiers for the purpose of computing compensation for our business partners and for the detection of fraudulent activities;
The Non-Personal Data we collect may be used or shared for the same purposes as detailed above with respect to Personal Data, as well as for the purpose of providing and improving our Services, internally within the Company to conduct business and marketing analysis. We may share such information with third party service provider partners (i.e., search feed providers, customer service, marketing assistance, ad tracking, service functionality and support, etc.) and other third parties, in order to assist us in analyzing how our Offer and Services are used, and in accordance with the terms of this Privacy Policy.
In addition, we may share your information with a parent company, subsidiaries, joint ventures, or other companies under common control solely if and when applicable or necessary for the purposes described in this Privacy Policy. We may share information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale), provided however, that our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
Furthermore, we may disclose your Personal Data to a third party for a "Business Purpose" (as defined under the CCPA). When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
DATA TRANSFER
We may process data in the US or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate steps to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data
COOKIE POLICY
We or our third-party service providers (i.e., Google Analytics) may use cookies. Cookies are small text files that are placed on your device by websites that you visit. They are widely used in order to make websites work more efficiently, as well as to provide the Services and functionalities for users, and make the interaction between you and the Offer or Services quicker and easier. Cookies enable you to improve your experience or remember your actions and preferences. More information about cookies is available at: www.allaboutcookies.org.
In Addition, information with respect to Google's use of the data from our use of Google Analytics Cookies, is available in Google's policies located at: www.google.com/policies/privacy/partners . We also recommend you to read about Google Analytics' currently available opt-outs available at: https://tools.google.com/dlpage/gaoptout/ .
Cookies opt-out
Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. For more information about your controls in this regard, you may review the following links:
Chrome
Firefox (Mozilla)
Opera
Microsoft
Safari
THIRD PARTY CONTENT
This Privacy Policy does not cover third-party services, third party providers or third party websites or your access and use of such. Those privacy practices may differ from ours, and we do not control the privacy and security practices and policies of these third parties and their sites. We are not, and won't be held responsible to such privacy practices. Thus, we recommend you to carefully review the applicable third-party privacy policy.
YOUR RIGHTS
You have the option to uninstall the Offering and reset your device settings whenever you choose.
Depending on applicable data privacy and related laws in your jurisdiction, you may have certain rights in respect of your Personal Data, including the right to access your Personal Data, request to delete, correct or amend it.
For more information regarding you rights please review our Privacy Rights Overview
If you wish to exercise any of your rights, please fill out the Privacy Rights Request ("PRR") form available here, and send it to our privacy team at: info@redtlv.com
DATA RETENTION AND SECURITY
We retain the information we collect solely for as long as required to fulfill the purposes for which it was collected. However, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal or tax requirements, or if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints. We use high security techniques to prevent your information from being accessed, used or disclosed without authorization, unlawfully destructed or accidental loss. However, although we make best efforts we can't provide 100% security and we cannot be held responsible for unauthorized or unintended access that is beyond our control. If you believe that your privacy was treated not in accordance with the provisions herein, or you have reasonable concern with that any person attempted to abuse our Service, please contact us info@redtlv.com
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/ .
CHANGES TO THE PRIVACY POLICY
We reserve the right, at our discretion, to revise or update this Privacy Policy at any time and every 12 months in the event required under applicable law. Such changes shall be effective upon publication of the amended Terms. The last revision will be reflected in the "Last Modified" heading. PLEASE MAKE SURE TO REVIEW THIS PRIVACY POLICY PERIODICALLY. In the event of material changes that will adversely affect your use of the Service or the data collection by us, we will make best efforts to provide you with notification through the Service.
Contact Us
If you have any questions about this Privacy Policy, please contact us at: