Who are “You”?
The information we collect, process and store varies depending on who you are. For purposes of this notice, there are two main categories of individuals, or “data subjects” as that term is used in the GDPR. They are (click on the one that applies to you):
- Consumers – people who purchase goods and services from merchants that are Radial’s clients.
- Employees – people that are current or past employees of Radial, and also applicants seeking employment with Radial.
This policy describes your rights with respect to the personal information about you that we collect and process. “Personal information” as used in the CCPA or “personal data” as used in the GDPR means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or a person’s device. Personal information does not include information that is de-identified or aggregated so that it no longer identifies you.
Data Subject Rights
These Data Privacy Laws provide various rights to individuals allowing them to know and control how personal information about them is used by companies. These rights are listed below and are described in more detail here.
- Access – the right to know what categories of personal information are collected and stored about you, and how it is used.
- Correction – the right to have your personal information corrected if it is incorrect.
- Portability – the right to obtain a copy of your personal information so that you may provide it to another service provider.
- Deletion – the right to have you personal information deleted from a company’s records.
All of the above rights are subject to certain exceptions, and if we are unable to comply your request, we (or our clients) will inform you.
Information we process about consumers
Radial provides various e-commerce services for our clients – merchants that sell goods and services on the Internet. Our clients provide Radial with information about you so that Radial can perform those services on behalf of our clients. These services include, among other things: warehouse order fulfillment and transportation, customer care services, payment processing, fraud prevention, order management systems, and omni-channel fulfillment services (such as pick up in store, ship from store and drop ship). To perform these services, information related to your order is provided to Radial by our clients, which includes, depending on the services we are performing, your name, shipping address, billing address, email address, phone number, order ID, order value, goods and services ordered, and payment account information, and other information we use in fraud prevention.
How we use and share information we collect about consumers
Radial uses this consumer personal information to provide our services to our clients. Radial does not use your information for any marketing purposes and Radial does not sell any of your personal information. Radial only shares consumer personal information with third parties as necessary to provide our services to our clients. For example, we provide your name, address and contact information to the parcel carrier we hire to ship the goods to you (such as the USPS, UPS and FedEx). When we are performing customer care services for our clients, we may record you name and other personal information as needed to assist you with your request or to help you with your order. We provide your payment account information to our payment processing banks and payment partners in order to process payments for our clients (such as Visa, MasterCard, American Express, Discover, and PayPal). We collect and process information about you in an effort to prevent criminals from fraudulently using your payment account information to purchase goods in your name without your permission. We also purchase personal information from and share personal information with third parties that provide similar fraud prevention services. And in general, Radial uses secure technology platforms and systems provided and hosed by various technology vendors (aka “cloud services”) subject to strict contract requirements that require these third parties to only use your information to provide services to Radial.
Consumer personal information rights and choices
Because you are providing your personal information to our clients when you purchase goods and services from them, Radial is not collecting the information from you, Radials’ clients are collecting your information. If Radial is providing customer care services on behalf of our client, Radial is collecting your personal information at the direction of our client and our client controls our use of your information. Therefore, if you wish to exercise your personal information rights described above, you must contact our client. Radial is unable to accept requests regarding personal information rights directly from our client’s consumers. Please visit our client’s website or our client’s customer care service for instructions on how to make a personal information rights request.
Information we collect about employees
Like any business, Radial collects, generates and stores personal information about its employees, past and present, as well as applicants seeking employment. If you are a job applicant, Radial may collect and store your application, resume, salary request, interview notes, credit review and background checks, and similar information, which may also include your name, address, and former names and addresses, your social security, driver’s license number, passport number and other applicable government ID numbers and copies of these documents. If you are a current or past employee, Radial may have on file your application records describe above, performance reviews, payroll and tax records, medical, financial and other employee benefit program records, and similar information, and if you are a past employee, the circumstances surrounding your departure. In some cases, we may also collect and store identifying information about you, such as your picture, voice, signature, and your thumbprint. We would also have records identifying your gender, age, race, citizenship, nationality, marital status, medical conditions and disabilities, veteran and military status, and also similar information about your family members to the extent they are receiving your employee benefits.
How we use and share information we collect about employees
Radial uses employee personal information to select our employees, to manage our employees, to manage payroll services, and to provide the various medical, financial and other employee benefit programs we offer. Radial shares employee personal information with third parties as necessary to operate our business and to provide you with the benefits described above. For example, we provide your personal information (and the personal information of your family members) to the medical insurance providers that you use through our employee benefits program. We provide certain payroll records to the government and to payroll processing companies. We may provide you information to organizations that perform financial credit checks and background checks on applicants before they are hired. And in general, Radial uses secure technology platforms and systems provided and hosed by various technology vendors (aka “cloud services”) subject to strict contract requirements that these third parties only use your information to provide services to Radial.
Your Rights and Choices
These Data Privacy Laws provide California and European Union residents with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights. As discussed above, if you are a consumer (a purchaser of goods or services from Radial’s merchant clients) then you must contact that merchant and submit your request with them. This merchant may in turn request that Radial and its other service providers assist in carrying out your request. If you are an employee of Radial or some other person that has provided personal information directly to Radial, you may submit a request to Radial as described below.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
Data Correction Rights
You have the right to request that we correct any your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, and the data correction details, we will correct your personal information in our records, unless an exception applies.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Denial of Requests
For example, we may deny your correction or deletion request if retaining the information is necessary for us or our service providers to (among other reasons):
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
- Enable internal uses that are consistent with reasonable expectations based on your relationship with us.
- Maintain records of past events and transactions, even the data is incorrect.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Making a Request and Exercising Access, Data Portability, Correction and Deletion Rights
If you are a current employee, to exercise the personal information rights described above, please contact your human resources representative or submit a verifiable request through the Radial Intranet.
If you are a past employee or prospective employee (an applicant) or a person other than an employee, but not a consumer, to exercise the personal information rights described above, please submit a verifiable request to us at firstname.lastname@example.org.
If you are a consumer (a purchaser of goods or services from Radial’s merchant clients), Radial is unable to accept requests regarding personal information rights directly from our client’s consumers. Please visit our client’s website or contact their customer care service for instructions on how to make a personal information rights request.
The verifiable request must:
- Provide sufficient information that allows us to verify you are the person you claim to be or an authorized representative of that person. Typically, we require your full name, mailing address and email address. We may also require that you show knowledge of certain other personal information that are not publicly known.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request and to carry out the request (if possible).
Response Timing and Format
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Under the CCPA, any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without undue hindrance.
We will not discriminate against you for exercising any of your rights under data privacy laws.
Changes to Our Privacy Notice
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, you may contact us at:
By e-mail: email@example.com
Attn: Data Privacy Officer
935 1st Avenue
King of Prussia, PA 19406