Relay Network LLC (“Relay”), located at 201 King of Prussia Road, Suite 161, Radnor, Pennsylvania, 19087, USA, operates the Relay Network (“Relay Network), a system that enables mobile phone users to manage their various business relationships efficiently, effectively and conveniently, by means of their mobile devices and online, with companies that are partners with Relay and with which those users have an ongoing account relationship as members, customers or employees. In this Policy, we sometimes refer to the communication and other services offered by Relay as the “Relay Services” or “Services”).
This Policy explains how Relay Network LLC (“Relay”) collects, maintains, uses and discloses personally identifiable information (sometimes referred to herein as “PII”) concerning Persons who use the Relay Services or communicate with Relay and its Partners by means of Partner Communications, Relay’s website, text messaging, Relay’s Web-based communications platform (the “Wire”) or other media of communication. The Policy does not describe the privacy practices of any other person or entity.
Relay’s practices concerning its collection, maintenance, use and disclosure of PII are set out exclusively in this Policy and in no other document. Any other privacy commitments by Relay in its contracts will not be materially less restrictive than this policy. This Policy might be changed from time to time. Your continued use of the Relay Services, or any decision to communicate with Relay by any means, constitutes your acceptance of the terms of this Policy, including any changes to the Policy.
Relay acquires PII from our Partners and from our Users, Prospective Users and other Persons. This Policy describes Relay’s privacy practices concerning information obtained from all of these sources.
Information Obtained from Relay Partners
Our Partners provide information to Relay concerning Individuals who are those Partners’ customers or members. That information might include, but is not limited to, names, addresses, telephone numbers, and identification numbers pertaining to Users and Prospective Users of the Relay Services.
In some cases, Relay may share PII and other information furnished by Partners to vendors that assist with provision of Relay Services. We require Relay’s vendors to use PII only for the intended purpose, we prohibit those vendors from selling or otherwise disclosing such PII to third parties and those vendors may be bound by contractual terms similar to those with Relay Partners.
Information Obtained from Users, Prospective Users and Others
Relay initiates communications in various ways with Users of Relay Services, persons identified by Relay Partners as Prospective Users, and others. Those communications include invitations to participate in the Relay Services, and information sent to Users who participate in the Relay Services, by means of the Relay Wire or otherwise, or Persons who initiate communication with Relay or Relay Partners. The media by which Relay sends the Partner Communications or conveys information to Users, Prospective Users and other Persons include text messages and messages conveyed by means of the Wire.
Individuals employ text messaging, electronic mail or submissions to the Wire, a Relay Website or a Relay Partner to provide information or make inquiries to Relay. As used in this Policy, the terms “Relay Website” or “Relay Websites” include the Relay Wire, the websites located at relaynetwork.com and my.relayit.com, and any other website that is controlled and operated by Relay.
Information that Relay acquires from Users, Prospective Users and other Persons may include the following:
- Mobile telephone numbers, carriers and other identifying information regarding devices used to facilitate the Services.
- Information voluntarily transmitted by Users, Prospective Users and other Persons to Relay and its Partners, using the communications channels furnished by Relay or other media.
- Names of companies and institutions with which Users and Prospective Users do business or have commercial relationships, and associated account information, voluntarily furnished to Relay by Users and Prospective Users so that Relay can facilitate the sending of service alerts and other communications from those businesses and institutions, as further described in Relay’s Terms of Service and User Agreement.
- Clickstream data, consisting of non-personal information transmitted from a computer or mobile device when interacting with a Relay Website. Clickstream data may include a device’s IP address, the type of Internet browser and operating system an Individual is employing, the pages and information accessed on a Relay Website, the time spent on a Relay Website, and the domain name of a Website from which an Individual linked to a Relay Website. Information of this kind permits a computer to establish a working connection to a Relay Website and navigate the website more effectively.
In some cases, Relay may share PII obtained from Individuals to vendors if required to assist with provision of Relay service, including the processing and fulfillment of inquiries and service requests. Relay’s vendors are contractually required use PII only for the intended purpose, and we prohibit those vendors from selling or otherwise disclosing such information to third parties. Relay cannot be responsible, however, for the privacy policies and practices of third party entity websites that have no contractual relationship with Relay but are linked to a Relay Website.
Relay’s Policies Applicable to Data from all Sources
Relay takes appropriate measures to protect the security and confidentiality of PII provided by its Partners and obtained from Individuals. Relay uses and discloses that personal information only for purposes related to the provision of Relay Services, and does not retain that information longer than is reasonably necessary to offer or furnish the Relay Services to the Individuals to whom the information pertains.
You should be aware that the Internet, and all electronic information transmission and storage systems, are subject to unauthorized intrusion and compromise. No operator of a website or information system can guarantee that it will not be penetrated by hackers or suffer a security breach through technical or human failure. Relay will protect information as required by law and our Relay Partner agreements, but we cannot guarantee there will be no loss, corruption or unauthorized disclosure of personal information.
If permitted by Relay’s contract with its Relay Partner, Relay compiles aggregate information into reports that Relay provides to Relay Partners and potential partners. Aggregate information is data derived from personal information submitted to a Relay website or collected from other sources that is not identifiable to individual persons. Relay may, for example, create a profile of its customer base according to zip codes and other factors. Relay’s reports based upon aggregate information contain no information that permits recipients of that information to identify or contact individual persons.
Relay will disclose personal information concerning Users, Prospective Users and others when required by legal process, or as necessary to protect the rights and safety of Relay, its customers, or the public.
Relay may transfer personal information to a purchaser or successor entity in connection with the sale of Relay Network LLC, a subsidiary or line of business associated with Relay Network LLC, or substantially all of the assets of Relay Network LLC or one of its subsidiaries, affiliates or lines of business subject to this Policy.
Note to Parents
Relay’s websites and services are not directed to children and do not knowingly collect personal information from children under the age of 13. When Relay acquires knowledge that a visitor to a Relay website is under the age of 13, Relay will take appropriate measures to avoid collection of personal information from that visitor or obtain verifiable parental consent.