Sungate Enterprises Ltd (RedLight Streets,” “we,” and “us”) respects the privacy of its users (“you”)
whom it may be shared, and your choices about such uses and disclosures. We encourage you to
us. By using our website, application or other online services (our “Service”), you are accepting the
for information on how to contact us.
Information we collect about you
In General. We may collect Personal Information, including Sensitive Data, and other information. “Personal Information” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person. Sensitive Data includes information, comments or content (e.g. photographs, video, profile, lifestyle) that you optionally provide that may reveal your ethnic origin, nationality, religion and/or sexual orientation. By providing Sensitive Data to us, you consent to the collection, use and disclosure of Sensitive Data as permitted by applicable privacy laws. We may also collect your geolocation information with your consent. We may collect this information through a website, mobile application, or other online services. By using the Service, you are authorizing us to gather, parse and retain data related to the provision of the Service. When you provide personal information through our Service, the information may be sent to servers located in the United States and countries around the world.
Information you provide. In order to register as a user with RedLight Streets, you will be asked to sign in. If you do so, you authorise us to access certain account information, such as your public profiles (consistent with your privacy settings), your email address, interests, likes, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your friends who might be common friends with other RedLight Streets users. You will also be asked to allow RedLight Streets to collect your location information from your device when you download or use the Service. In addition, we may collect and store any personal information you provide while using our Service or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos, a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other RedLight Streets users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.
Information from other sources. RedLight Streets is part of Sungate Enterprises Ltd family of businesses. We may obtain both personal and non-personal information about you from other businesses, business partners and other third parties.
Use of technologies to collect information.We use various technologies to collect information from your device and about your activities on our Service.
Information collected automatically. We automatically collect information from your browser or device when you visit our Service. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location while our application is actively running, and the referring website address.
Cookies and use of cookie and similar data. When you visit our Service, we may assign your device one or more cookies or other technologies that facilitate personalisation to facilitate access to our Service and to personalize your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Service, such as the pages you visit, the time and date of your visits and the links you click. If we advertise, we (or third parties) may use certain data collected on our Service to show you RedLight Streets advertisements on other sites or applications.
Pixel tags. We embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).
Mobile device IDs. If you're using our app, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs (for iOS 6 and later), instead of cookies, to recognize you. We do this to store your preferences and track your use of our app. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in “Settings” on your iPhone. Ad companies also use device IDs or Advertising IDs to track your use of the app, track the number of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device IDs to track information about app usage.
Information collected by third-parties for advertising purposes. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Service and elsewhere. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-masked or non-obscured personal information to third parties. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org). Opting out will not decrease the number of advertisements you see. To opt-out of cookies that may be set by third party data or advertising partners, please go to http://www.aboutads.info/choices/
How we use the information we collect
In General. We may use information that we collect about you to:
deliver and improve our products and services, and manage our business;
manage your account and provide you with customer support;
perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
website or mobile application analytics;
verify your eligibility and deliver prizes in connection with contests and sweepstakes;
perform functions or services as otherwise described to you at the time of collection.
Job applicants. If your Personal Information is submitted when applying for a position with our company, the information will be used solely in connection with considering and acting upon your application. We may retain your Personal Information, but only for the purpose of considering your application for current or future available positions. This information, which may include your name and contact information, prior education and experience, and other information you provide to us, may be shared with third-party service providers retained by us to collect, maintain and analyse candidate submissions for job postings.
In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.
With whom we share your information
Information Shared with Other Users. When you register as a user of RedLight Streets, your RedLight Streets profile will be viewable by other users of the Service. Other users (and in the case of any sharing features available on RedLight Streets, the individuals or apps with whom a RedLight Streets user may choose to share you with) will be able to view information you have provided to us directly or through social media, such as your Facebook photos, any additional photos you upload, your first name, your age, approximate number of miles away, your personal description, and information you have in common with the person viewing your profile, such as common Facebook friends and likes. If you swipe right or use voting buttons to say “yes” to a person, you will be able to chat with that person if they swipe right or use voting buttons to say “yes” to you, e.g., when you have a “match.” If you chat with your match, of course your match will see the content of your chat
Service providers. We may share information, including personal and financial information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
Other Situations. We may disclose your information, including personal information:
In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Aggregated and/or non-personal information. We may use and share non-personal information we collect under any of the above circumstances. We may also share it with other Sungate Enterprises Ltd companies and third parties to develop and deliver targeted advertising on our Service and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis, advertising, marketing, or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reﬂect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. We may also share your geolocation information in de-identified form with Sungate Enterprises Ltd companies and third parties for the above purposes. To opt out of the sharing of your geolocation information, please discontinue use of the RedLight Streets application.
Do Not Track disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in their 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. We are committed to providing you with meaningful choices about the information we collect and that is why we provide the opt-out links above. However, we do not recognize or respond to any DNT signals, as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
How you can access and correct your information
If you have a RedLight Streets account, you have the ability to review and update your personal information within the Service by opening your account and going to settings. Applicable privacy laws may allow you the right to access and/or request the correction of errors or omissions in your personal information that is in our custody or under our control. Our Privacy Officer will assist you with the access request.
We will respond to requests within the time allowed by all applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization to which it was disclosed.
In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold. For security purposes, not all personal information is accessible and amendable by the Privacy Officer. If access or corrections cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Your choices about collection and use of your information
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Service because such information may be required in order for you to register as user; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions.
Our Service may also deliver notifications to your phone or mobile device. You can disable these notifications by going into “App Settings” on the app or by changing the settings on your mobile device.
You can also control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.
How we protect your personal information
We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
You agree that we may communicate with you electronically regarding security, privacy, and administrative issues, such as security breaches. We may post a notice on our Service if a security breach occurs. We may also send an email to you at the email address you have provided to us. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at email@example.com
Information you provide about yourself while using our Service
Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from children under the age of 18.
Onward transfer and consent to international processing
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by RedLight Streets from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
No Rights of Third Parties
This Notice provides information about data we collect, use, and share, and our commitment to using the personal data we collect in a respectful fashion.
Why Do We Collect Information and Data?
We collect, process and retain personal information from you and any devices you may use when you use our Services, or provide to us on a web form, or when you update your information or otherwise correspond with us regarding our Services. Additionally, we may collect personal information from third parties. We collect information for the following purposes:
- To process your transactions and contact you, as necessary
- To verify your identity
- To collect payment for your use of the Service
- To troubleshoot problems with the Service
- To detect and prevent fraud and other illegal uses of the Service
- To enhance and simplify the user experience
- To send you marketing notices, service updates, and promotional offers
- To send transaction alerts to you and/or the recipient of your remittance
How Do We Collect Information?
We collect personal information:
- Directly provided by you when you use our Services;
- Automatically through your use of our Services;
- From using cookies, web beacons, and similar technologies; and
- From other third party sources.
What Kinds of Personal Information Do We Collect?
Information That You Give Us
The information that we collect directly from you includes:
- Information that you provide us in the course of using the Service, such as your name, address, e-mail address, and telephone number. We may also collect certain sensitive information from you including your bank account number, credit card number, date of birth and social security number, and other identification documents we may request to validate your identity for the safety and security of establishing your Account with the Service.
- To facilitate our Service, we request certain third party personal information from you such as your recipient's full name, physical address, email address, and phone number. We may also collect from you the recipient's sensitive financial information including their name, bank account and routing number. If you give us personal information about someone else, you must do so only on their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal information according to our Privacy Notice.
- Information about your usage of the Service, including your transaction history, and how you choose to pay/fund your remittance, and to whom you use the Service to send or receive money, along with the recipient’s collection method.
You decide how much information to share with us in most cases, but not sharing required information may limit your ability to engage in certain activities, such as payment information required to complete a transaction.
Information Collected Automatically Through Your Use of the Service
When you use or interact with our Site and Services, we receive and store information generated by your activity, like usage data and other information automatically collected from your browser or mobile device. The Information that we automatically obtain from you includes:
- Information about the hardware and software you use when accessing the Service
- Your IP address, phone number and geolocation data obtained from your mobile device
- The pages you access on this website, and other websites that you visit prior to accessing the Service.
Information Collected Using Cookies, Web Beacons, and Similar Technologies
COOKIES, beacons, tags and scripts are used by SUNGATE and our partners, affiliates, or analytics or service providers. These technologies are used:
- To enhance and simplify the user experience on our home page and throughout our site, to remember users’ settings (e.g. language preference, preferred country of remittance, and for authentication); and
- To analyse trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
The information collected may include your IP address; browser type and version; preferred language; geographic location using IP address or the GPS, wireless, or Bluetooth technology on your device; operating system and computer platform; the full Uniform Resource Locator (URL) clickstream to, though, and from our Site, including date and time; and areas of our Site that you visited. We also may log the length of time of your visit and the number of times you visit and purchase or use the Services.
We may assign you one or more unique identifiers to help keep track of your future visits.
We may supplement the information we collect with personal information from third parties. For example, we may collect and use demographic information that is publicly available, additional contact information, and information obtained by identity verification services and credit reporting agencies, as allowed by applicable national laws.
Our Web site includes Social Media Features, such as the Facebook, LinkedIn and Twitter buttons and Widgets or interactive mini-programs that run on our site. These Features may:
- Collect your IP address, which page you are/were visiting on our site; and
- Set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site.
When May We Share or Disclose Your Personal Information?
We do not sell, share or rent the information we collect to third parties for their promotional purposes unless we receive your permission to do so. Nevertheless, we may share information about you (including non-public, non-personally identifiable information) with:
- Third-party service providers under contract with SUNGATE that help us with our business operations, such as transaction processing, fraud prevention, collections, email communications, live chat and marketing. These service providers are authorised to use your personal information only as necessary to provide these services to us.
- Third-parties that we partner with to offer additional products and services, such as long-distance telephone minutes, but only when you elect to receive information about those additional products and services.
- In the event of the sale, acquisition or merger of some or all of our assets, your personal information might be a part of the transferred assets. We shall notify you in the event of such an occurrence by placing a notice on our website.
- Law enforcement and government officials, but only in connection with a formal request, subpoena, court order, or similar legal procedure, as well as circumstances where we believe in good faith that disclosure is necessary to comply with the law, report suspected illegal activity, or investigate violations of our User Agreement.
Uses of Personal Information (other than providing services)
Provide, Improve and Personalise our Services
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, verify security, and to improve marketing, analytics, or site functionality.
Personalize our Advertising and Marketing Communications
If our site contains links to other web sites. Sungate Enterprises Ltd is not responsible for the privacy practices or the content of these other web sites. We encourage you to familiarise yourself with the privacy practices of these other sites prior to submitting your personal information to them.
We may choose to use Google AdSense to publish ads for and on this site. When you view or click on an ad, a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. You may opt-out of the use of this cookie by visiting Google’s Advertising and Privacy page: https://policies.google.com/technologies/ads.
Testimonial and Referrals
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via details mentioned in the Contact Us section.
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name, email address and phone number. We will automatically send your friend a one-time email inviting him or her to visit the site. Sungate stores this information for the sole purpose of sending this one-time email, and for tracking the success of our referral program.
Withdrawal of Consent
Federal and state laws allow you to restrict the sharing of your personal information in certain instances. However, these laws also state that you cannot restrict other types of sharing. Because we have chosen to refrain from certain types of data sharing, the only type of sharing of your personal information that you may restrict is as follows:
- If, after giving us your permission to share your personal information with third parties, with whom we market our jointly offered products, you later decide that you no longer want us to share such information, you may Contact Us by email
- You may also opt-out from promotional emails to you by accessing your E-mail Preferences & selecting the "Unsubscribe" function present in each email we send out.
Access to Your Personal Information and Retention
We will honor any statutory right you may have to access, modify or erase your personal information. Where you have a statutory right you to access, modify or erase your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases and in accordance with applicable national laws, but will give you reasons if we do so.
You can access, modify or update or delete your personal information submitted on our Site by logging into your account and changing your preferences. You may also contact us using the Contact Us details below.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
What Security Measures Do We Have?
We protect your information using administrative, organizational, physical and technical safeguards, including firewalls and data encryption, to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our website, data centres, systems, and other assets
Other Important Information
Data Transfers to Other Countries
Sungate is headquartered in the United Kingdom, and we have operations, entities, and service providers in the United Kingdom and throughout the world, including in India. As such, we and our service providers may transfer your personal information to, store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
If you are located in the European Economic Area, we provide adequate protection for the transfer of Personal Informationto countries outside of the EEA through a series of inter-company agreements based on the Standard Contractual Clauses authorized under the EU Data Protection Directive 95/46/EC.
Sungate does not offer services to minors and does not knowingly collect Personal Information from children under theage of 13. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us using the Contact Us details below and we will promptly respond.
How to contact us