Effective Date: January 1, 2025

This Privacy Policy describes the policies and procedures of Redapt Inc. ("We," "Us," or "Our") regarding the collection, use, disclosure, and protection of personal information. We are committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the General Data Protection Regulation (GDPR), the Children's Online Privacy Protection Act (COPPA), and other relevant regulations such as the California Online Privacy Protection Act (CalOPPA) and California's Shine the Light Law.

Redapt Inc. is the data controller for GDPR and a "business" under CCPA/CPRA. Our contact details are provided at the end of this policy. This policy applies to information collected through our website (https://www.redapt.com/) and related services. It does not apply to information collected offline.

We utilize HubSpot, a customer relationship management (CRM) and marketing automation platform, as a key service provider to facilitate data collection, management, and communications. HubSpot's features include form management for subscriptions and inquiries, email marketing tools with consent-based opt-in mechanisms, analytics for website performance, and built-in compliance tools such as data processing agreements (DPAs) that align with GDPR and CCPA/CPRA requirements. These features enable secure handling of personal information, consent tracking, and fulfillment of data subject rights requests.

You consent to the practices described in this policy by accessing or using our website or services. If you do not agree, please discontinue use.

Interpretation and Definitions

Words with initial capitalization have the meanings defined below and apply in singular and plural forms.

• Account: A unique account created for you to access our services.
• Business (under CCPA/CPRA): Refers to Redapt Inc. as the entity that collects and processes personal information of California residents.
• Company: Redapt Inc., located at 14051 NE 200th Street, Woodinville, WA 98072, USA.
• Consumer (under CCPA/CPRA): A natural person who is a California resident.
• Cookies: Small files placed on your device to track browsing activity.
• Data Controller (under GDPR): Redapt Inc., which determines the purposes and means of processing personal data.
• Data Subject (under GDPR): You, as the individual whose personal data is processed.
• Device: Any device accessing our services, such as a computer or mobile phone.
• Do Not Track (DNT): A browser setting signaling preference against online tracking.
• Personal Data/Information: Any information relating to an identified or identifiable individual, including under CCPA/CPRA (e.g., data that identifies or could reasonably be linked to you) and GDPR (e.g., name, identification number, online identifiers).
• Sale (under CCPA/CPRA): Disclosing personal information for monetary or other valuable consideration.
• Service: Our website and related offerings.
• Service Provider: Third parties processing data on our behalf, considered data processors under GDPR.
• Sharing (under CCPA/CPRA): Disclosing personal information for cross-context behavioral advertising.
• Usage Data: Automatically collected data, such as page visit duration.
• You: The individual or entity using our services.

Collecting and Using Your Personal Information

Types of Personal Information Collected

We collect personal information when you subscribe to our newsletter, respond to a survey, fill out a form, or interact with our website. Categories include:

• Identifiers: First name, last name, email address, business phone number.
• Professional or employment-related information: Company/employer name, job title.
• Internet or network activity: Browsing history, IP address, device information (via cookies or similar technologies).

You may visit our site anonymously, but certain features require providing personal information. We do not collect sensitive personal information (e.g., health data, precise geolocation) unless necessary for service delivery and with your explicit consent where required. We do not process purchases on our website or collect information about products or services purchased.

Collection sources include direct submissions (e.g., forms managed via HubSpot), automated technologies (e.g., cookies), and third-party service providers.

How We Collect Your Personal Information

• Directly from you via forms or communications, often processed through HubSpot's form and CRM tools.
• Automatically, this is done through cookies, tracking pixels (e.g., Google Analytics, and potentially Meta Pixel or LinkedIn Insight Tag for analytics and advertising insights), and usage data. HubSpot's tracking code may also collect visitor interaction data to support personalization and analytics.
• From third parties assisting in website operations or analytics.

Purposes for Processing Your Personal Information

We process personal information for the following purposes:

• To personalize your experience and respond to your needs.
• To improve our website based on feedback and usage data.
• To enhance customer service and support.
• To administer contests, promotions, surveys, or site features.
• To send periodic emails about company news, updates, or related products (with opt-in for marketing lists, managed via HubSpot's email automation features).
• To manage customer relationships and marketing campaigns through HubSpot's CRM platform.

Under GDPR, legal bases include:

• Consent (e.g., for marketing emails or cookies).
• Performance of a contract (e.g., fulfilling service requests).
• Legitimate interests (e.g., website improvement, analytics), balanced against your rights.

We retain personal information only as long as necessary for these purposes, typically up to 7 years for legal compliance or until you request deletion, unless longer retention is required by law.

Use of Cookies and Tracking Technologies

We use cookies to compile aggregate site traffic and interactions data for better experiences. We utilize Google Analytics to analyze website usage and visitor behavior. Additionally, we may use Meta Pixel and LinkedIn Insight Tag to gain insights into advertising performance and site interactions. HubSpot's tracking technologies, including cookies and pixels, monitor website visits, form submissions, and user engagement, enabling features such as consent management and personalized content delivery. Third-party service providers may assist, but they are contractually obligated to use data only for our business purposes and keep it confidential.

Cookie categories:

• Essential: For site functionality.
• Analytics: To understand visitor behavior (e.g., via Google Analytics or HubSpot).
• Marketing: For targeted content (if applicable, via Meta, LinkedIn, or HubSpot pixels).

You can manage cookies via browser settings. In compliance with CalOPPA, we honor Do Not Track (DNT) signals by not tracking users who enable them. For more details, see our cookie notice or banner on the website.

Disclosure of Your Personal Information

We do not sell, trade, or transfer your personal information to outside parties for monetary or other valuable consideration. However, we may disclose it to:

• Service providers (e.g., HubSpot for CRM, marketing automation, and analytics; hosting; analytics via Google Analytics; and potentially advertising insights via Meta Pixel or LinkedIn Insight Tag; payment processors if applicable) are bound by confidentiality agreements and data processing terms compliant with CCPA/CPRA and GDPR. HubSpot acts as a data processor under our instructions, with features ensuring secure data handling and compliance support.
• Third parties for legal compliance, site policy enforcement, or protection of rights, property, or safety.
• In business transfers (e.g., mergers), with notice to you.

Non-personally identifiable information may be shared for marketing or advertising. Under CCPA/CPRA, we do not "sell" or "share" personal information as defined, but we disclose categories like identifiers, professional information, and internet activity to service providers for business purposes.

In the past 12 months, we have disclosed the following categories for business purposes: identifiers, professional information, and internet activity.

Data Security

We implement reasonable security measures, including encryption, firewalls, and access controls, to protect personal information from unauthorized access, alteration, or disclosure. HubSpot's platform incorporates additional security features, such as role-based access controls and encryption in transit and at rest, to further safeguard data processed. However, no method is entirely secure, and we cannot guarantee absolute security.

International Data Transfers

As a U.S.-based company, HubSpot primarily processes data in the USA. For EU/UK residents under GDPR, transfers outside the EEA use Standard Contractual Clauses or other approved mechanisms to ensure adequate protection. As a service provider, HubSpot maintains GDPR-compliant data transfer mechanisms, including EU-U.S. Data Privacy Framework certification where applicable.

Your Privacy Rights

You have rights regarding your personal information. To exercise them, contact us using the details below. We respond within statutory timelines (e.g., 30 days under GDPR, 45 days under CCPA/CPRA) and do not discriminate against you for exercising rights. HubSpot's tools assist in managing and fulfilling these requests efficiently.

General rights include:

• Access: View your personal information.
• Correction: Update inaccurate data.
• Deletion: Request erasure, subject to exceptions (e.g., legal obligations).
• Objection/Opt-Out: Stop processing for certain purposes.
• Portability: Receive data in a structured format.
• Withdraw Consent: Where processing relies on consent.

Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights:

• Know: Request categories and specific personal information collected, sources, purposes, and third parties it was shared with (twice per 12 months).
• Delete: Request deletion, subject to exceptions.
• Opt-Out of Sale/Sharing: We do not sell or share, but a "Do Not Sell or Share My Personal Information" link will be provided if practices change.
• Limit Sensitive Data: We do not process sensitive data for inferred characteristics.
• Non-Discrimination: No denial of services or price changes for exercising rights.
• Shine the Light: Request details on disclosures for third-party direct marketing (none in the past year).
• Metrics (2024): Requests received: 0; Complied: 0; Denied: 0; Median response time: N/A.

Under CalOPPA, we disclose tracking practices and honor DNT signals.

Rights for EU/UK Residents (GDPR)

If you are in the EU/UK, you have rights to access, rectification, erasure ("right to be forgotten"), restriction, objection, and portability. We process based on lawful grounds and do not appoint a Data Protection Officer as we do not meet thresholds. Complaints can be filed with your supervisory authority (e.g., ICO in the UK).

Children's Online Privacy Protection Act (COPPA) Compliance

We comply with COPPA and do not collect information from anyone under 13. Our website and services are directed to individuals at least 13 years old. If we discover such data, we will delete it promptly. Parents/guardians may contact us for review or deletion.

Under California's "Online Eraser" Law, minors under 18 may request removal of posted content.

Changes to This Privacy Policy

We review this policy annually and may update it for legal, operational, or regulatory reasons. Changes will be posted here with the updated effective date. Significant changes will be notified via email or website notice. Continued use constitutes acceptance.

This policy was last updated on July 22, 2025.

Contacting Us

For questions, rights requests, or complaints, contact:

Redapt, Inc.
14051 NE 200th Street
Woodinville, WA 98072
USA

Phone: 425.882.0400
Email: results@redapt.com

For verified requests, we may require identity confirmation. Authorized agents may submit on your behalf with proof of authorization.