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Effective Date:

May 2021

  • Information We Collect

  • Use of Personal Information

  • Disclosure of Information

  • Cookies, Analytics and Targeted Ads

  • Interest-Based Advertising

  • Direct Marketing

  • International Transfers

  • Security

  • Retention

  • Third-Party site

  • Use of Website by Children

  • Your Rights

  • Your California Privacy Rights

  • Changes to this Privacy Notice

  • Contact Us

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Information We Collect

Red Thread Digital is a privately owned company. This Privacy Notice applies to your use of the website. Red Thread Digital (RTD) may collect personal information directly from you, such as when you register for news and information, contact us online or submit forms through our site. Red Thread Digital is the controller of your personal information and the processing of personal information is also undertaken by RTD for your personal information. We may also collect personal information from third parties or automatically through your use of the site.

For the purpose of this Privacy Notice (“Notice”), “personal information” means any information that identifies or could be used to identify an individual person, including similar terms such as “personal data” or “personally identifiable information” and "sensitive personal information" means any personal information unauthorized disclosure or misuse of which may jeopardize the rights or property of, or is likely to damage the reputation or physical mental health or lead to discriminatory treatment of the individual concerned, or as otherwise defined under applicable law. Please also be sure to check the end of this Notice for country-specific information that is providing to as required by the relevant applicable law.

The following sections set forth the categories of personal information RTD has collected in the preceding 12 months and how RTD uses and shares such personal information.

Information Collected Directly

We collect information (including sensitive personal information, where applicable) that you provide to us or share on the site, including:

  • Registration Information and Requests. Our site and other information available on our site can be accessed without registering. However, you will be required to register in order to use or access some of our services. The information that we collect will vary depending upon the context of your request, but for general inquiries, we require your first and last name and contact information, such as Company Name, telephone number and email address and other relevant information relating to your request. Generally, fields marked with an asterisk are mandatory for processing your inquiry or your registration, other details are optional.

  • Communications. When you email us, call us or contact us, we maintain records about our interactions and communications with you.

  • Customer Service and Support. We also maintain records related to customer support and customer service-related requests, including the nature of the request, in order to process questions or comments directed to our customer service team, or to settle complaints. For questions or comments directed to our customer service team relating to an order or invoice, or in the event of a product complaint, we may require additional information about the product, for example, product size, gender, time and place of purchase and additional information about previous inquiries.

  • Comments and Content. Some areas of the site may allow you to comment, share or post other content. When you view this content, we keep a record of our content and it may be viewable by other users of the site. You may ask us to remove such content as set out below.

  • Marketing and Surveys. If you participate in our direct marketing activities, for example if you fill out a participation or answer card or register for the RTD newsletter, we will process the personal information required for each of these. If you used our online store and a purchase process is not completed, we may send you a reminder email. If you have signed up to participate in a competition or similar advertising campaign, we may use the personal information provided by you to process your participation. For more information, please refer to the conditions of participation for the respective campaign. Where required by applicable law, we will obtain your consent prior to sending you any direct marketing. If you have given consent to receive direct marketing email communications RTD will use the personal information provided by you to further discuss your interest in the company or our products and services; and to send you information that may be of interest regarding the company, its affiliates, and its partners, such as information about special offers, events, e-commerce activities, market research, consumer or customer surveys, competitions and similar advertising campaigns.

  • E-Commerce. If you purchase products from us directly, for example from our online store, we will require additional information, such as billing and delivery address, and bank and/or credit card details. When you use our online store, we will use personal information to process contracts and orders that you have placed through our website, any inquiries relating to contracts and orders, as well as assess your creditworthiness when purchasing a product, for which we may contract a third-party service provider. When you purchase a product, we may contact you in order to ask you for your opinion on the purchase or the product.

  • Business Relationship Information. We work with external professionals, contractors, suppliers, experts, consultants and others in the operation of our business. For example, when we deliver our services and otherwise make our products and services available, we may engage with suppliers, contractors, consultants and others who provide services or products to us. We also engage with customers and partners related to the provision of our products and services. We may collect information through these third parties. We collect information such as business contact information, accounting and payment related information and other information related to our business relationship with a third party. We may also conduct due diligence and background checks subject to applicable law to ensure the reliability of third parties with whom we conduct business.

Automatically-Collected Information

When you visit the site, some data is automatically transferred from your browser to our server, in order to offer you a better service with personalized information and to make it easier for you to use our site. We use cookies, pixel tags, web beacons and similar technologies to automatically collect information when users access or use the site. This data is collected and processed by us or by external service providers on our behalf and includes: information about you collected through your use of our services, including log files, IP address, app and device identifier, advertising ID, location info, browser type and operating system, device type, domain name, the website that led you to our services, the website to which you go after leaving our services, the dates and times you access our services, and the links you click and your other activities within the services. For more information, please refer to the Cookies section below.

Monitoring of Communications

With your consent and subject to applicable laws we may monitor and record your calls, emails and other communications with us. We do this for a variety of purposes which include the following: to maintain the security of our communications systems and procedures, for quality control and staff training purposes, fraud detection and prevention, and when we need to see a record of what has been said between us. We will also monitor for regulatory compliance (where applicable) as well as crime prevention and detection purposes.

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Use of Personal Information

In the course of conducting our business, we use (with your consent where required by applicable law) personal information (and sensitive personal information, where applicable) to provide and improve our services, to process employment inquiries, to provide information about our products and services, to respond to requests and to otherwise communicate with you and others.

  • Providing Support and Services: to provide and operate our services and the site, communicate with you about your use of the site, respond to your inquiries, provide troubleshooting, fulfill your orders and requests, process your payments, and complaints and inquiries, provide technical support, and for other customer service and support purposes.

  • Operating our Business: we may use your information to identify usage trends in the use of our site and analyze the effectiveness of our communications; to detect, prevent, investigate fraud and including (cyber) security monitoring and prevention; to validate your ability to access or use certain products or services; to operate and expand our business activities; where necessary to the administration of our general business, accounting, record keeping and legal functions; and as part of our routine business administration, such as training, compliance auditing and similar internal activities.

  • Research, Development and Reporting: we may use information to develop, enhance, improve or modify our products and services; to better understand how our products and services impact you and those for whom you care; to track and respond to concerns, including engaging in regulatory monitoring and reporting obligations related to adverse events, product complaints and patient safety, or to conduct data analysis and audits.

  • Personalization: to tailor content we send or display on the site in order to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.

  • Analytics and Improvement: to better understand how users access and use the site and other products and services, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.

  • Evaluating and Engaging With Third Parties: to identify, evaluate and engage with third parties such as contractors, suppliers and business partners; to conduct due diligence, such as background checks on contractors and suppliers in accordance with applicable law.

  • General Business Operations: where necessary for the administration of our general business, accounting, record keeping and legal functions.

  • Anonymous and De-identified Information: We may de-identify information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry, and for other research and analytics purposes.

  • Marketing, Surveys and Promotions: for direct marketing and promotional purposes, to send you newsletters, special offers or promotions, and contact you about our products or services, or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.

  • Protect Our Rights: to protect the site and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Notice.

  • Legally Required: to comply with the law or legal proceedings, such as subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

We will, where required by applicable law, obtain consent from you if we wish to use your personal information for purposes other than those stated in this Notice.

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Disclosure of Information

To facilitate RTD’s global operations, personal information may need to be shared with and transferred between RTD affiliates. With your consent, RTD affiliates may access and use your personal information as described in this Notice. In general, we disclose the personal information we collect as follows: 

  • RTD Affiliates. As a global company, your personal information may be shared amongst our affiliated and subsidiary companies, who are subject to this Notice when processing your personal information.

  • Service Providers. We may share your information with third-party service providers, whose services we use for data storage and analytics, for web hosting, data analysis, IT technology, infrastructure, and security, including without limitation with third parties whose services we use to provide customer services, for example for communicating with you by email or phone, for market research, carrying out surveys, handling payment transfers, advisory services, maintenance, and other similar services. We take steps to confirm that our service providers are capable of providing appropriate security and protection and will agree to adequate privacy and security contractual terms.

  • Third-Party Advertising and Marketing. Third-party companies that we work with to display online advertising that is more relevant may collect cookie IDs, IP address and other identifiers as well as information about the pages you visit on our site and other website, to enable them to display advertising for products and services that may be of interest to you when you visit our website or other website.

  • Business Transfers. We may disclose or transfer information, including personal information, as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), including related to due diligence conducted prior to such event where permitted by law.

  • Legally Required. We may disclose your information if we are required to do so by the law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order) of any jurisdiction.

  • Protect our Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of RTD, our customers, or others.

  • Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

The categories of personal information we have shared with these parties for business purposes in the preceding 12 months, where applicable, are set forth above in the section addressing Information We Collect.

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Cookies, Analytics and Targeted Ads

We and our service providers use cookies, pixels, java script and other tracking mechanisms to track information about your use of our site and services, and we may combine this information with other information, including personal information, we collect about you. We may also work with third party ad networks, analytics companies, measurement services and others to display advertising on our site, and to manage our advertising on third party site, mobile apps and online services.


Cookies are small text files that are stored on your computer or mobile device. Cookies are used in order to make website work, or work in a better, more efficient way or to allow us to track your activities while using our Site. We use “session cookies” which are deleted as soon as you close your browser, and temporary/permanent cookies, which are stored on your computer or mobile end device for a longer period, until they expire, or are deleted. This helps us to recognize you and remember important information that will make your use of a website more convenient (for example by storing preference settings).

In general, the use of cookies is activated by your browser; however, you can turn off this function. If you do not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies or to delete them.

To learn more about cookies, please click here. If you choose to decline cookies, then some or all of the features, functionality and promotions available through the website may not be available to you.

Clear GIFs, Pixel Tags and Other Technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. Unlike cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our site to, among other things, track the activities of our site users, help us manage content, and compile statistics about usage of our site. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log Files

Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

Third-Party Analytics

We use third-party services, such as Google Analytics (more information or opt-out) and Adobe Analytics (opt-out) to analyze the usage of our website. We utilize these tools to gather information about users to help enhance the user experience and to improve our site. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our site with other information they have collected for their own purposes. Please review these third party's privacy policies, as this Notice does not cover such uses of data by third parties.

Do-Not-Track Signals

Our site do not currently respond to do-not-track signals. For more information about do-not-track signals, please click here. However, you may choose to, disable certain tracking mechanisms (such as cookies) as discussed above.

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Interest-Based Advertising

On some of our site, we may work with third party ad networks, analytics companies, measurement services and others (collectively “ad companies”) to display advertising on our site, and to manage our advertising on third party site, mobile apps and online services. We and these third party ad companies will, and by using our site you consent that they may use cookies, pixels tags, and other tools to collect activity information on our site (as well as on third party site and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to display you more relevant ads and content and to evaluate the success of such ads and its content.

You may also obtain more information about targeted or “interest-based advertising” and opt out of many ad networks at the industry website below:

You may also manage your cookie preferences in your browser settings. If you wish to do so please visit:

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Direct Marketing

From time to time, we may send periodic promotional emails to you that we think may be of interest to you, including newsletters, special offers or promotions, in relation to our products or services. We would also like to share your name and email address with other entities within RTD so that we or they may send you information that may be of interest regarding them and their special offers, events, e-commerce activities, market research, consumer or customer surveys, competitions and similar promotional campaigns, but we also cannot do so without your consent. You may opt-out of these communications at any time, and where required by law we will obtain your prior consent to send you such communications.

If you would like to opt-out of receiving further electronic communication from RTD, and/or wish to stop RTD from disclosing your personal information for marketing purposes you may opt-out of such communications by following the opt-out instructions contained in the email, or you can contact us to withdraw your consent. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails with information relating to your account or any services you have requested or received from us.

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International Transfers

As a global company, we may transfer your personal information to, access or store it in the United States, the European Union, and other jurisdictions in which we (or our service providers) operate and subject to requests from law enforcement from other jurisdictions. Some of these jurisdictions, including the United States may not provide equivalent levels of data protection as your jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection comparable to the protection under applicable law in the jurisdiction from which we collect such personal information, including through appropriate written data processing terms and/or data transfer agreements. Where required by law we will obtain your consent prior to such transfer. If you are located in China, please note that RTD will only transfer your personal information (and sensitive personal information, where applicable) outside of China as permitted by applicable law and where RTD is satisfied that adequate levels of protection are in place to protect the integrity and security of your personal information or adequate security measures (such as written data processing/transfer agreements) are adopted and compliant with applicable privacy and data protection law.

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We have implemented specific organizational, technical, and administrative measures to protect personal information under our control from unauthorized access, use, or disclosure, including, as appropriate, encryption of personal information (and in particular, sensitive personal information), privacy and security impact assessments, and secure access controls among other things. While the security safeguards we have put in place are routinely reviewed and updated, the security of any data transmissions and data storage systems cannot be completely guaranteed.

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As a general rule, we will retain your personal information as long as needed to fulfill the purposes outlined in this Notice, and as otherwise necessary to fulfill our legal obligations, resolve disputes, maintain appropriate business records, enforce our agreements or for such longer period as required by applicable law. The retention period depends on the information and the reason for which we have collected it. For example, we generally retain personal data records related to technical support and customer service requests for seven years, unless a longer or shorter retention period is required by law, is necessary in the course of legal obligations, to resolve disputes, maintain appropriate business records, and enforce our agreements proceedings or is otherwise needed for a particular purpose under applicable law.

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Third-Party site

This Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties. The inclusion of a link on the website does not imply endorsement of the linked site by us or by our affiliates. In some cases, we may permit you to use third-party payment services to make payments. If you wish to make a payment using a payment service, you will be directed to a webpage that is hosted by the payment service and not by us. Any information that you provide through this page will be subject to the applicable payment service’s privacy policy, rather than this Notice. We have no control over, and are not responsible for, any payment service’s use of information collected through any payment service page.

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Use of Website by Children

Our site are not directed towards children and we do not encourage children to participate in providing us with any personal information. We do not knowingly collect any personal information from children under the age of thirteen (13) without verifiable parental consent. If you have reason to believe that a child under the age of 13, without a parent or guardian's consent, has provided personal information to us through the site, please contact us at We will take steps to delete the information as soon as possible should we learn that we have collected the personal information of a child without first receiving verifiable parental consent.

Minors under 18 years of age may have the personal information that they provide to us deleted by sending an email to requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

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Your Rights

RTD takes reasonable steps to keep your personal information accurate, up to date and complete. You may have a right to request access to, correction of, and deletion under certain circumstances of, your personal information, subject to applicable law. Subject to applicable law, you may also have the right to withdraw your consent or change your scope of consent. If you wish to exercise these rights, please contact us at You also have the right to lodge a complaint with us and with a supervisory authority if you consider that the processing of your personal information infringes applicable law.

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. In addition, in some circumstances based on applicable law, you may request that we cease using or sharing personal information about you with our business partners, by contacting us as explained below We will seek to honor those requests consistently with applicable law.

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Your California Privacy Rights

This Privacy Policy describes how we may share your information for marketing purposes, as described above. California residents are entitled to request and obtain from us once per calendar year information about any of your personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us as explained below.

If you are a California resident, California law also provides you with the following rights with respect to your personal information:

  • The right to know what personal information we have collected, used, disclosed and sold about you. To submit a request to know, you may email us at

  • The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may email us at

  • The right to request to opt-out of the sale of your personal information. To submit a request to opt-out of sale, you may email us at

When you exercise these rights and submit a request to us, we will verify your identity by asking you to log in to your account if you have one with us. If you do not have an account with us, we may ask for your email address, order numbers of previous orders of our products and services, the date of your last purchase from us, or other similar data elements to verify your identity. We also may use a third party verification provider to verify your identity.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

In addition and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Notice, what information RTD has “sold” about you. Please be assured that RTD does not sell or rent your personal information to third parties in exchange for money. Instead, there are instances where RTD has shared personal information in order to provide customers of its RTD brand with personalized services or customized offers to improve your shopping or online experiences on the RTD website or elsewhere. Depending on the circumstances and the contractual obligations in place, this sharing may be considered a “sale” under California law and you may have the right to request that we stop such sharing as more fully set forth below. This sharing may include:

  • identifiers such as a device or browser identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, Internet Protocol address, online identifier, and other forms of persistent identifiers;

  • commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories; and Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with website, applications or marketing.

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Changes to this Privacy Notice

We may update this Notice from time to time to reflect changes, and will post changes by updating the Notice (and effective date) on this page. If we make any material changes that affect how we treat your personal information, we will attempt to notify you in advance, such as by prominently posting a notice on this website or by sending you a notification and seeking your consent to any material changes as required by applicable law. We encourage you to periodically review this website and our Notice to understand how RTD protects your personal information.

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Contact Us

If you have questions or concerns regarding this Notice or complaints regarding the processing of your personal information, please contact the RTD Privacy Office at

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