Privacy Policy

RDA Corporation is committed to protecting the privacy of information you provide to us. Accordingly, RDA provides this privacy policy to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can request access, correction, portability, or deletion of such information (our “Privacy Policy”). DEFINITIONS

Use and Disclosure of Your Personal Information We may use and disclose your Personal Information only for the following purposes:

We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this Privacy Policy applicable to, Personal Information. Disclosure of Personal Information to Third Parties We may disclose Personal Information to the following types of third parties for the purposes described in this Privacy Policy:

Data Collected for and by our Customer As a Customer, you may import into our system Personal Information you have collected from your Recipients. We have no direct relationship with your Recipients and for this reason, you are responsible for making sure you have the appropriate permission for us to collect and Process information about those Recipients. We may transfer Recipient Personal Information to our Service Providers. All Service Providers enter into a contract with us that protects Recipient Personal Information and restricts their use of any Recipient Personal Information consistent with this Privacy Policy. As part of our Services, we may use and incorporate the information you have provided, we have collected from you, or we have collected about Recipients into features. If you are a Recipient and no longer want to be contacted by one of our Customers, please unsubscribe directly from that Customer’s emails or contact the Customer directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Customer of your request. Content of Emails Sent When a Customer sends an email to a Recipient, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for sending confidential information and most emails end up in an unencrypted inbox. Please do not use the Services to send confidential information. Sometimes we review the content of our Customer’s email campaigns to make sure they comply with our Terms of Use. To improve that process, we employ software that helps us find email campaigns that may violate our Terms of Use. Our employees or independent contractors may review those particular email campaigns. This benefits all Customers who comply with our Terms of Use because it reduces the amount of spam being sent through our servers and helps us maintain high deliverability. Anonymous and Aggregated Information RDA may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and RDA may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within RDA and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. YOUR CHOICE You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy. General Where you have consented to RDA’s Processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email address or other identifying value that is associated with your Personal Information in order for RDA to segregate out the use and retention of such Personal Information. Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, RDA will comply with the law or contract.

Sensitive Personal Data “Sensitive Personal Data” is a subset of Personal Information, which due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Data includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (a) race or ethnic origin; (b) political opinions; (c) religious or philosophical beliefs; (d) trade union membership; (e) genetic data; (f) biometric data where Processed to uniquely identify a person; (g) health information; (h) sexual orientation or information about the individual’s sex life; or (i) information relating to the commission of a criminal offense. RDA does not collect Sensitive Personal Data from you. However, if we do ever collect it, we will, prior to disclosing it to a third party or Processing it for a purpose other than its original purpose or the purpose authorized subsequently by the individual, obtain your explicit consent. Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, RDA will comply with the law or contract. Email Communications An “Unsubscribe” button will be provided in each marketing communication sent to you by RDA so that you can opt-out of such communications. However, we may continue to send transaction-related emails regarding products or Services you have requested in response to such request including, for example, a support inquiry. We may need to send you certain communications regarding the Services and you will not be able to opt out of those communications, including for example, communications regarding updates to our Terms of Use or this Privacy Policy.

“Do Not Track” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like RDA should interpret DNT signals. Therefore, RDA does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. INTERNATIONAL TRANSFER RDA primarily stores Personal Information sent or collected via or by RDA in the United States and the European Union (as applicable), in the cloud, our servers, the servers of our group of companies, or the servers of our Service Providers. To facilitate our global operations, we may transfer and access such information from around the world. To carry out the email delivery function of the Platform, we may need to transfer such information around the world. Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to RDA, you consent to the transfer and storage of Personal Information in these locations. RIGHTS OF ACCESS, RECTIFICATION, PORTABILITY, ERASURE, AND RESTRICTION Your Personal Information You may seek confirmation regarding whether RDA is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of applicable data protection laws. Where otherwise permitted by applicable law, you may contact us to request access to, receive, port, restrict Processing, seek rectification or request erasure of Personal Information held about you by RDA. Such requests will be carried out in accordance with applicable laws. Although RDA makes good faith efforts to provide you with access to your Personal Information, there may be circumstances in which RDA is unable to provide access, including for example, where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If RDA determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, RDA will take reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Recipient Personal Information As a data processor for our Customers, RDA Processes data, which may include Recipient Personal Information on behalf of our Customers. We will not use, share, distribute, or reference any such Recipient Personal Information except as provided in the applicable agreement between us and our Customer, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Recipient Personal Information and you wish to exercise any rights you may have to access, receive, port, restrict Processing, seek rectification, or request erasure, please inquire with the applicable Customer directly. Because RDA personnel have a limited ability to access Recipient Personal Information, if you wish to make your request directly to RDA, please provide the name of the applicable RDA customer. We will refer your request to that Customer, and will support them as needed in responding to your request within the timeframe required by applicable law. RETENTION RDA retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. SECURITY We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the Processing and the nature of the Personal Information. RDA accounts require a username and password to log in. You must keep your username, password, and API key(s) secure, and never disclose them to a third party. OTHER RIGHTS AND IMPORTANT INFORMATION Children Due to the nature of RDA’s business, our Services are not marketed to minors. RDA does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Personal Information directly collected by us, but does not apply to the Personal Information provided to us by third party services and organizations or from our Customers regarding their Recipients (please refer to the terms of their respective privacy policies). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, we will promptly delete that information.

Links to Third Party Websites Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those websites, your information is governed by such websites’ privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Changes RDA may update this Privacy Policy from time to time as it deems necessary in its sole discretion. RDA will provide notification of any material changes to this Privacy Policy through the Website or as otherwise required by applicable law. We encourage you to review this Privacy Policy periodically to be informed regarding how RDA is using and protecting your information and to be aware of any policy changes. Your continued relationship with RDA after the posting or notice of any amended Privacy Policy will constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by RDA.