RedJade PRIVACY Policy

Tragon Corporation d/b/a RedJade ("RedJade", "we", "us") provides a web-based software solution ("Platform") to enterprises and educational institutions ("RedJade Clients") through which RedJade Clients can design and create experience surveys ("Surveys") as well as collect and process responses from private individuals who are invited by RedJade Clients to participate in these Surveys ("Survey Participants").

We host the Platform on, and for the purposes of this Privacy Policy the Platform is part of, the RedJade website located at www.redjade.net ("Website") and the RedJade mobile app ("Mobile App").

The Website has a number of pages that are accessible to the general public ("Public Pages"). The Platform itself, however, can only be accessed by RedJade Clients and, upon invitation by RedJade Clients, by Survey Participants.

We receive information from persons who visit the Public Pages, RedJade Clients and Survey Participants but we handle this information in different ways. This Privacy Policy therefore consist of two parts.

Part 1 of this Privacy Policy describes how we collect and handle information from RedJade Clients, including but not limited to:

  • the type of information we collect from RedJade Clients;
  • how such information is collected from RedJade Clients;
  • how we handle information collected from RedJade Clients; and
  • when we share information collected from RedJade Clients.

Part 2 of this Privacy Policy describes how we collect and handle information from Survey Participants, including but not limited to:

  • the type of information we collect from Survey Participants;
  • how such information is collected from Survey Participants;
  • how we handle information collected from Survey Participants; and
  • when we share information collected from Survey Participants.

Even if you are only browsing our Public Pages, our servers automatically record certain information that your browser sends when you visit a website ("Usage Data"). For details of the type of Usage Data our servers collect from you and how we use this please see the provisions dealing with Usage Data in Part 2 of this Privacy Policy.

Please read the sections of this Privacy Policy that apply to you carefully to understand our views and practices regarding your personal information and how we will treat it. By accessing the Website, you are accepting and consenting to the practices described in this Privacy Policy.

If you have any questions with regard to this Privacy Policy, please contact us by mail at 350 Bridge Parkway, Redwood Shores, CA 94065 or by email to support@redjade.net

Part 1: Privacy for RedJade Clients


I. Type of Information RedJade Collects

We generally collect three different types of information for, and in relation to, RedJade Clients (together "your information").

We collect and handle certain information that you provide to us in connection with the creation or administration of your RedJade client account from time to time. This includes for example the name of the RedJade Client, names of contact persons at the RedJade Client, RedJade user names and details of a RedJade Client’s authorized RedJade users, office phone numbers, email addresses, billing information associated with your RedJade client account and any information that you give to us when you contact RedJade customer support. We refer to this information as "Client Account Data".

We also host, process and store for you (in accordance with your instructions and permissions) the Surveys you create using the Platform and any responses to Surveys collected by you using, or otherwise uploaded by you into, the Platform from time to time. We refer to this information, and any other data that you (or your Survey Participants) may upload into the Platform from time to time, as "Client Content".

Finally, whenever you interact with the Website we collect certain information that we collectively refer to as "Usage Data".

This may include:

  • Information such as the manufacturer and model of your mobile device, your Internet Service Provider ("ISP"); your device’s Internet Protocol ("IP") address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; pages of the Website that you visit, the time spent on those pages or interacting with certain portions of the Mobile App, information you search for on the Website and Mobile App, access times and dates; and other statistics;
  • Referral Data. If you arrive on the Website from an external source (such as a link on another website or in an email), the Website records information about the source that referred you to the Website.
  • Geolocation Data, which may be inferred based on your IP address. The Website collects and uses geolocation data to monitor performance and availability of the Platform globally. The Website will request your express permission to collect your geolocation data.
  • Information from page tags. We may use third party tracking services that employ collies and page tags (also known as web beacons) to collect aggregated and anonymised data about visitors to our Website.

We use a third party service provider, Google Analytics, to assist us with the collection of Usage Data.

Usage Data is generally not associated with you. Whenever we do associate Usage Data with Personal Information, we will treat it as Personal Information.

For this purpose, "Personal Information" refers to, in relation to a private individual ("Consumer"), information about such Consumer that can be used to contact or identify him/her. Personal Information includes, but is not limited to, a Consumer’s full name, phone number, email address, home and business postal addresses, and any other information that could be used to personally identify the Consumer.

If you are a RedJade Client located in the European Union please note that we are the data controller for any Client Account Data and Usage Data we collect from you from time to time. With regard to your Client Content, however, we are only a data processor.

II. Methods RedJade Uses to Collect Information

A. Client Account Information and Client Content

Client Account Information and Client Content is information that we collect from you (or, on your behalf and instructions, Survey Participants) directly.

B. Usage Data

Usage Data, on the other hand, is information about you that we collect indirectly or passively when you interact with the Website. We may use a number of different techniques and technologies to collect Usage Data. For example, we may use cookies, log files, clear gifs, pixel tags, embedded scripts, and/or other technology used to monitor use of the Website.

(i) Cookies

As is regular practice on many websites, the Website uses cookies to distinguish you from other users of the Website and to help us understand which parts of the Website are more popular and how much time users spend there. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Since cookies are now used as industry standard, most devices automatically accept cookies, but you can usually change your device’s browser settings to decline them. If you prefer not to enable cookies, you may choose to disable all or some of them. Please note however that if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Website.

(ii) Tracking

Usage Data is also collected automatically by the Website’s servers and software. For example, because the Website automatically collects Usage Data for all users that visit the Website, all Website sessions will be tracked. Additionally, the Mobile App collects Usage Data and sends it to the Website servers to facilitate the services provided to you through the Mobile App. By accessing the Website you agree that we may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to facilitate the provision of software updates, product support and other services to you related to the Website and/or Mobile App.

Additionally, in some of our email messages to you, RedJade may use a "click-through URL" linked to content on the Website. When you click onto one of these URLs, you will pass through our server before arriving at the destination Web page. RedJade tracks this click-through data to help us determine RedJade Client interest in certain subject matters and measure the effectiveness of these RedJade client communications. You can avoid being tracked in this way by not clicking text or graphic links in emails from RedJade.

Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. Please note that the Website does not accept or process such Do Not Track signals or similar mechanisms.

(iii) Web Beacons, Page Tags, Clear Gifs and Pixel Tags.

We may use web beacons, page tags and/or clear gifs or pixel tags, which are tiny graphic images, in order: (i) to advise us of what parts of the Website you have visited, (ii) to measure the effectiveness of any searches you perform, and (iii) to enable us to send emails to you in a format that you can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to you.

III. RedJade’s Use of Information

We generally use the information we collect from you, and on your behalf from Survey Participants, in connection with providing you with our services in accordance with the terms of the hosted services agreement that you have entered into with us ("HSA") and all other agreements entered into between you and us from time to time.

This includes, without limitation:

  • To provide you with the Hosted Services (as defined in the HSA), including but not limited to technical support which will require us to access your Client Account Data and/or Usage Data and may, in limited circumstances, require us to access your Client Content;
  • In the case of Client Account Data, to contact you about our services or your RedJade client account, for example service-related announcements, billing-related matters, changes to our services or changes to this or other RedJade policies. These are communications that you cannot opt out of as they are required to provide our services to you under the HSA;
  • In the case of Usage Data, for the technical administration of the Website, including to monitor and analyze use of the Website, to increase the functionality and user-friendliness of the Website, and to better tailor the Website to RedJade Clients’ and Survey Participants’ needs;
  • To respond to legal requests (if we receive a subpoena or other legal request, we may need to access and inspect your information to determine how to respond);
  • As part of our efforts to keep the Website safe and secure; and
  • To prevent potentially illegal activities.

IV. RedJade’s Sharing and Disclosure of Information

RedJade’s policy is not to share your information with third parties other than as specified in the HSA, or as set out below, or where you expressly consent to our sharing of such information with a third party.

We may share your information with third parties under the following circumstances:

A. Other Business Partners and Service Providers

We work closely with certain business partners, sub-contractors and service providers and we may provide access to your information to these service providers so that they can assist us in providing our services to you. For example, we may employ third party companies and individuals for any of the following: to facilitate the Website; to provide the Website or portions of the Website on our behalf; to perform related services, including without limitation, maintenance services, database management, hosting services, support services, email services, fulfillment, data processing, web analytics, monitoring services, and improvement of the features or functionality; or to assist us in analyzing how the Website is being used.

By way of example, we currently use a service provider, New Relic, located in the United States, to monitor the servers on which we host the Platform. The service provider receives a small amount of technical information about Client Content (but no actual Client Content) as needed solely to diagnose any issues that might arise with respect to the operation of the servers.

We also use a mail service, MailChimp, located in the United States, to send out any emails that RedJade Clients instruct the Platform to send to Survey Participants on their behalf. In order to do so, the service provider will receive and utilize the email addresses of Survey Participants that are provided by RedJade Clients for the purpose of sending the relevant communication.

Further, we use a help desk ticket system service provider, Fresh Desk, located in the United States, to create support tickets whenever RedJade Clients have issues that arise where they need our technical support. This service provider will gather your contact information as needed on the tickets in order for RedJade to provide technical support to you.

We give relevant persons working for some of these providers access to your information, but only to the extent strictly necessary for them to perform their services for us. We also implement reasonable contractual and technical protections to ensure the confidentiality of your information is maintained and used only for the provision of their services to us.

B. Business Transfers

As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about a business’ customers is often a transferred business asset. If ownership of all or substantially all of our business activities changes, or if we undertake a corporate re-organisation (including a merger or consolidation) or any other action or transfer between entities of the Tragon group of companies, you expressly consent to us transferring your information to the new owner or successor entity so that such owner or successor entity can continue to provide our services.

C. Compliance with Law and Protection of RedJade and Others

We may disclose your information if we receive a request or are otherwise legally obliged to disclose this, whether pursuant to a subpoena, an order issued by a court or other governmental authority of competent jurisdiction or otherwise and, on advice of legal counsel, determine that disclosure is required and/or permitted under applicable law.

D. Aggregate Site Use Information about Usage Data

We may release de-identified and aggregated Client Account Data and/or Usage Data (without revealing any Personal Information) to advertisers and other third parties in order to promote or describe use of the Platform.

V. Third Party Service Providers, Links to other Sites

This Privacy Policy applies only to the Website. This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with RedJade that you may visit, e.g., via a link provided through the Website or on a website maintained by any third party. RedJade does not control the privacy policies of other websites to which we may provide hyperlinks. We cannot be responsible for the privacy practices or the content of such non-RedJade websites, and we do not control the practices of any of the third party websites or service providers to whose sites we link. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.

VI. Security, Data Location and other Important Information

A. Security

Please see our Security Statement for details about RedJade’s security infrastructure and practices.

B. Data Location and International Data Transfer

RedJade controls and operates the Website from its offices in Bolder, Colorado, United States and servers in Frankfurt, Germany. Usage Data is stored on our servers in Colorado, United States but all Client Account Data and Client Content are stored on servers located in Frankfurt, Germany.

Any Personal Information that may be contained in your Client Account Data may accordingly be collected and/or transferred to, hosted, processed and used in the United States and/or Germany and any Personal Information that may be contained in your Client Content will be collected and/or transferred to, hosted, processed and used in Frankfurt, Germany. If we are requested by you, or required, to access your Client Content, any Personal Information contained in such Client Content may be transferred to and/or processed and used in the United States.

Your information may also be processed in, and transferred or disclosed to, countries in which our service providers are located or have servers. Currently all relevant service providers are located in the United States.

If you access the Website, you acknowledge and agree that your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. By submitting any information to us, whether through the Website or otherwise, you further expressly agree to the transfer of such information and the collection, use, and disclosure of your information in accordance with such applicable laws and this Privacy Policy.

It is a RedJade Client’s responsibility to ensure that it is entitled to transfer all Personal Information that may be contained in its Client Account Data and/or Client Content to us so that we can lawfully collect, transfer, process, use and share the same in accordance with the HSA, any other agreements entered into between us and them, this Privacy Policy and the RedJade Client’s instructions and permissions from time to time. As such, a RedJade Client is required to comply with all applicable data protection laws and requirements, including but not limited to the provision of all necessary information to Survey Participants and other relevant Consumers and the obtaining of any consents that may be required.

C. Safety of Children and COPPA

RedJade is committed to protecting the privacy of children. A person must be be eighteen (18) years or older in order to have a RedJade User Account and obtain access to, or use of the Platform from RedJade. Persons under the age of eighteen (18) years old may only obtain access to, and use of, the Platform at the permission of a "head of household" who is their parent or legal guardian and who has a "head of household" RedJade User Account.

However, RedJade does not have any visibility into or knowledge of who it is a RedJade Client is directing to use the Platform or who it is that a RedJade Client is collecting data from or what data the RedJade Client is uploading into the Platform from time to time, including whether or to what extent this data includes Personal Information, what type of Personal Information and/or whether the RedJade Client has collected the Personal Information from any particular person, including children.

If RedJade itself believes that a person under the age of eighteen (18) has registered as a "head of household", or is not old enough to consent to and be legally bound by this Privacy Policy, or is using the Platform without permission from his/her parent or guardian, RedJade may, at any time, in its sole discretion, and with or without notice: (i) terminate such person’s access to or use of the Platform (or any portion, aspect, or feature of them), or (ii) delete any content or information that such person has posted through the Platform.

D. Access to Personal Information Conatined in Client Account Data

RedJade Clients have the right to access any Personal Information held by RedJade as part of such RedJade Client’s Client Account Data in accordance with the provisions of the German Data Protection Act. This right can be exercised by contacting us by email to customer support at support@redjade.net.

VII. Changes to this Privacy Policy

We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on the Website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you continue to use the Website beyond the advance-notice period, you will be considered as having expressly consented to the changes in our Privacy Policy. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you must discontinue use of our services.

PART 2: Privacy for Survey Participants


I. Type of Information RedJade Collects

We generally collect two different categories of information relating to you and your use of the Website (together "your information").

A. Client Content

All Surveys created by a RedJade Client using the Platform, all responses to Surveys that you submit to the Website and/or that a RedJade Client uploads into the Website, and all information that you submit to the Website when you create a RedJade User Account upon invitation by a RedJade Client, are private to and the property of such RedJade Client. The same applies to all other data that is uploaded by a RedJade Client into the Platform from time to time. We may provide RedJade Clients with certain statistical, technical information with regard to how long it takes Survey Respondents to respond to a particular survey question or how long it takes Survey Respondents to complete a survey, so called "Response Time Information". In this Privacy Policy we refer to all of the aforesaid information together as "Client Content".

Each RedJade Client is responsible for its Client Content and manages it through the use of the Platform.

RedJade Clients may collect personally identifying information from you as part of Survey answers collected through the Website or as part of the information submitted by you to the Platform when you create a RedJade User Account upon invitation of a RedJade Client. If you are a Consumer, personally identifying information refers to information about you that can be used to contact or identify you ("Personal Information"). Personal Information includes, but is not limited to, your full name, phone number, email address, home and business postal addresses, and any other information that could be used to personally identify you. RedJade Clients who create the Surveys may also collect non-identifying personal information from Survey Participants, such as zip code (on its own), gender, age, and individual preferences.

Please note that we are not responsible for and that we do not have any visibility into or knowledge of queries made by RedJade Clients to you as part of a Survey or whether any responses that you may give to a Survey, and that are uploaded into the Platform, include any Personal Information. We also do not have any visibility into how RedJade Clients then process, use or share any information that you give as part of your responses to a Survey using the Platform or as part of the set up of a RedJade User Account.

If you have any query with regard to a Survey you wish to participate in, please therefore directly contact the RedJade Client who has created the Survey.

We also strongly encourage you to view the privacy notice and/or privacy policy of the relevant RedJade Client directly to see what information (and in particular Personal Information) it may collect from you in connection with the Survey or as part of the set up of a RedJade User Account and how it may use and/or share that information.

B. Usage Data

Whenever you interact with the Website we collect certain information from you indirectly and we refer to this information as "Usage Data".

This may include:

  • Information such as the manufacturer and model of your mobile device, your Internet Service Provider (ISP); your device’s Internet Protocol ("IP") address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; pages of the Website that you visit, the time spent on those pages or interacting with certain portions of the Mobile App, information you search for on the Website and Mobile App, access times and dates; and other statistics;
  • Referral Data. If you arrive on the Website from an external source (such as a link on another website or in an email), the Website records information about the source that referred you to the Website.
  • Geolocation Data, which may be inferred based on your IP address. The Website collects and uses geolocation data to monitor performance and availability of the Platform globally. The Website will request your express permission to collect your geolocation data.
  • Information from page tags. We may use third party tracking services that employ collies and page tags (also known as web beacons) to collect aggregated and anonymised data about visitors to the Website.

We use a third party service provider, Google Analytics, to assist us with the collection of Usage Data.

Usage Data is generally not associated with you. Whenever we do associate Usage Data with Personal Information, we will treat it as Personal Information.

II. Methods RedJade Uses to Collect Information

A. Methods RedJade Uses to Collect Client Content.

We collect Client Content, on behalf of our RedJade Clients, from you directly when you respond to Surveys using the Platform, or when you set up a RedJade User Account upon invitation of a RedJade Client.

B. Methods RedJade Uses to Collect Usage Data.

Usage Data, on the other hand, is information about you that we collect indirectly or passively when you interact with the Website RedJade may use a number of different techniques and technologies to do so. For example, we may use cookies, log files, clear gifs, pixel tags, embedded scripts, and/or other technology used to monitor use of the Website.

(i) Cookies

As is regular practice on many websites, the Website uses cookies to distinguish you from other users of the Website and to help us understand which parts of the Website are more popular and how much time users spend there. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Since cookies are now used as industry standard, most devices automatically accept cookies, but you can usually change your device’s browser settings to decline them. If you prefer not to enable cookies, you may choose to disable all or some of them. Please note, however, that if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Website.

(ii) Tracking

Usage Data is also collected automatically by the Website’s servers and software. For example, because the Website automatically collects Usage Data for all users that visit the Website, all Website sessions will be tracked. Additionally, the Mobile App collects Usage Data and sends it to the Website servers to facilitate the services provided to you through the Mobile App. By accessing the Website you agree that we may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to facilitate the provision of software updates, product support and other services to you related to the Website and/or Mobile App.

Additionally, in some of the email messages that a RedJade Client may send using the Platform, we may use a "click-through URL" linked to content on the Website. When you click onto one of these URLs, you will pass through our server before arriving at the destination Web page. RedJade tracks this click-through data to measure the effectiveness of these RedJade Client communications. You can avoid being tracked in this way by not clicking text or graphic links in emails.

Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. The Website does not accept or process such Do Not Track signals or similar mechanisms.

(iii) Web Beacons, Page Tags, Clear Gifs and Pixel Tags.

We may use web beacons, page tags and/or clear gifs or pixel tags, which are tiny graphic images, in order: (i) to advise us of what parts of the Website users have visited, (ii) to measure the effectiveness of any searches users perform, and (iii) to enable the Platform to send emails in a format that users can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to users.

III. RedJade’s Use of Information

Client Content is owned and managed by our RedJade Clients and we treat Client Content as private to and the property of our RedJade Clients. You can find further details of the purposes for which we use Client Content in Part 1 of this Privacy Policy.

We use Usage Data to manage and improve our services to RedJade Clients, the management and technical administration of the Website, including to monitor and analyze use of the Website, to increase the functionality and user-friendliness of the Website, and to better tailor the Website to RedJade Clients’ and Survey Participants’ needs.

IV. RedJade’s Sharing and Disclosure of Information

Anything you expressly disclose in your Survey responses or in connection with the establishment or use of your RedJade User Account, if applicable, will be part of the Client Content of the RedJade Client who designed the relevant Survey and will be provided to and shared with such RedJade Client.

Please see Part 1 of this Privacy Policy for details how we share Client Content.

If you are a Survey Respondent based in California, USA, please note that, by responding to Surveys and/or submitting information to the Website upon invitation of a RedJade Client, you consent to RedJade sharing your information with such RedJade Client and to the possibility that such RedJade Client may use such information for direct marketing purposes. If you do not consent to this, then do not respond to Surveys and/or do not submit information to the Website. We strongly encourage you to view the privacy notices and/or privacy policy of the relevant RedJade Client directly to see what information (and in particular Personal Information) it may collect from you in connection with their Survey or the set-up of a RedJade User Account and how it intends to use and/or share this information.

V. Security, Data Location and other Important Information

A. Security

Please see our Security Statement for details about RedJade’s security infrastructure and practices.

B. Data Location and International Transfers

RedJade controls and operates the Website from its offices in Bolder, Colorado, United States and servers in Frankfurt, Germany. Usage Data is stored on our servers in Colorado, United States but all Client Account Data and Client Content are stored on servers located in Frankfurt, Germany.

Any Personal Information that is part of a RedJade Client’s Client Content will accordingly be collected, transferred to and/or hosted, processed and used in the United States and/or Germany. If we are requested by a RedJade Client, or otherwise required, to access such RedJade Client’s Client Content, any Personal Information contained in such Client Content may be transferred to and/or hosted, processed and used in in the United States.

Any Personal Information contained in Client Data may also be processed in, and transferred or disclosed to, countries in which our service providers are located or have servers. Currently all relevant service providers are located in the United States.

If you access the Website, you acknowledge and agree that your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

C. Access to Your Information

Other than in the case of Usage Data, we only process your information on behalf of RedJade Clients. If you have any questions about a Survey or if you want to access, update or delete anything any responses you have submitted to a RedJade Client through the Website please contact the relevant RedJade Client direct. Equally, if you would like to have access to or correct any Personal Information that you have provided as part of any responses to a Survey you have submitted to a RedJade Client through the Website, please contact the relevant RedJade Client direct.

The creation of a RedJade User Account by a Survey Participant is optional, but can be done if a Survey Participant is invited to do so by a RedJade Client. All Survey Participants who have created an account on the Website may review, update, correct or delete the Personal Information in their registration profile using the relevant functions of the Website. If you completely delete all such information, then your RedJade User Account may become deactivated. We may retain an archived copy of your records as required by law, the HSA or for legitimate business purposes.

D. Safety of Children and COPPA

RedJade is committed to protecting the privacy of children. A person must be be eighteen (18) years or older in order to have a RedJade User Account and obtain access to, or use of the Platform from RedJade. Persons under the age of eighteen (18) years old may only obtain access to, and use of, the Platform at the permission of a "head of household" who is their parent or legal guardian and who has a "head of household" RedJade User Account.

However, RedJade does not have any visibility into or knowledge of who it is a RedJade Client is directing to use the Platform or who it is that a RedJade Client is collecting data from or what data the RedJade Client is uploading into the Platform from time to time, including whether or to what extent this data includes Personal Information, what type of Personal Information and/or whether the RedJade Client has collected the Personal Information from any particular person, including children.

If RedJade itself believes that a person under the age of eighteen (18) has registered as a "head of household", or is not old enough to consent to and be legally bound by this Privacy Policy, or is using the Platform without permission from his/her parent or guardian, RedJade may, at any time, in its sole discretion, and with or without notice: (i) terminate such person’s access to or use of the Platform (or any portion, aspect, or feature of them), or (ii) delete any content or information that such person has posted through the Platform.

VI. Changes to this Privacy Policy

We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on the Website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances. If, after being informed of these changes, you continue to use the Website beyond the advance-notice period, you will be considered as having expressly consented to the changes in our Privacy Policy. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you should cease responding to any Surveys and using your RedJade User Account, if applicable.