PRIVACY POLICY

Effective Date: Apr 9, 2025

RLL Racing ( Activated by Spark Compass ) Owned by Total Communicator Solutions, Inc. respects your privacy and is committed to protecting it through this Privacy Policy. This document explains how we collect, use, disclose, and safeguard your information when you use the RLL Racing mobile application (“App”).

1. Information We Collect

1.1 Personal Data

  • Name
  • Email address
  • Profile image (captured via camera or uploaded from your photo library)

1.2 Device and Usage Data

  • Device ID
  • IP address
  • App interactions (e.g., polls, surveys, fan corner activities, banners, & tiles)

1.3 Location Data

  • Precise and coarse location (used to detect your presence near race events or Gimbal beacons for triggering content and awarding points)
  • Background location access is used solely for beacon detection when the app is not actively open.

1.4 Bluetooth Data

  • Bluetooth is used to detect proximity to Gimbal beacons installed at various locations.

1.5 Camera and Photos Access

  • Used exclusively for setting and updating your profile photo within the app. Photos are stored securely and not shared externally.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To personalize your user experience.
  • To trigger location-specific or beacon-specific notifications.
  • To award reward points for interactions.
  • To provide access to special features like Fans Corner, Surveys, and Polling.
  • To improve app performance and functionality.

3. Sharing of Information

We do not sell or rent your personal information. However, we may share your information in the following ways:

  • Authorized service providers (e.g., cloud providers, notification platforms) who process data on our behalf.
  • Government agencies if required by law or in the interest of protecting or exercising our or others’ legal rights (e.g., law enforcement or court proceedings).
  • Business transactions such as a merger, sale, or reorganization of the company, where your information may be transferred as part of the assets.

Notwithstanding the above, we reserve the right to share and use aggregated data for our own business purposes.

4. Cookies and Other Technologies

The App may use cookies and other tracking technologies such as pixel tags and web beacons.

These technologies help us understand your behavior, facilitate and measure the effectiveness of offers, and improve the overall user experience.

  • Cookies: We use cookies to identify users, track app usage, and provide a more personalized experience. Information in the cookies is only accessible to RLL Racing and its affiliates and will not be shared with third parties unless otherwise stated.
  • Pixel Tags and Web Beacons: These are used to track app activity and interactions, which help us improve the app and measure its performance.

5. User Rights

Depending on your location, you may have the following rights concerning your personal data:

  • Access to the data we hold about you.
  • Request deletion of your personal information.
  • Withdraw consent to data collection by disabling permissions or deleting the app.

If you wish to exercise any of these rights, please contact us as described in the “Contact Us” section below.

6. Data Security

We implement appropriate technical and organizational measures to protect your data.

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

7. Third-Party Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of other websites or services. We encourage you to review the privacy policies of those third parties before submitting any personal data.

8. Tracking & Analytics

This app may use third-party services that collect user data for analytics purposes. If tracking is used, we comply with Apple’s App Tracking Transparency (ATT) framework and will request user consent before collecting data for tracking purposes.

9. Minors

We do not knowingly collect personally identifiable information (PII) from minors, i.e., persons under 18 years of age. If we learn that we have collected PII from a minor, we will take steps to delete the PII as soon as possible.

10. Disclosure to Third Parties in the Course of RLL Racing’s Business

At times, RLL Racing may make certain PII available to strategic partners who work with us to provide products and services, or help our clients provide you with offers and opportunities. Our strategic partners include companies who provide services such as information processing, fulfilling customer orders, delivering products, managing and enhancing customer data, providing customer service, assessing your interest in our clients’ products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your PII.

PII will only be shared by RLL Racing and its affiliates to provide or improve the App or technologies and intellectual property used in the App. PII will not be shared with third parties for their marketing purposes.

11. Disclosure to Others as Required by Law

It may be necessary – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – for RLL Racing to disclose your PII in their custody or control. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate under applicable law.

RLL Racing may also disclose information about you if we determine that disclosure is reasonably necessary to enforce the terms of the End-User License Agreement (EULA) or protect our operations or clients or customers.

Additionally, in the event of a reorganization, merger, or sale, we may transfer any and all PII we have collected to the relevant third party authorized by law to receive it.

12. Protection of PII

RLL Racing takes precautions – including administrative, technical, and physical measures – to safeguard your PII against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. We will also do everything in our power to protect user data offline. All sensitive information is stored on secure and encrypted servers. Only employees who need the information to perform a specific job (e.g., a customer care representative) are granted access to PII, and they are required to lock their stations when they leave.

All employees, consultants, and independent contractors are kept up to date on our security and privacy practices. Every quarter and whenever new policies are implemented, RLL Racing employees are reminded about the importance of keeping your data secure and safe at all times. The servers with PII are stored in a secure environment.

13. Integrity and Retention of PII

We make it easy for you to keep your PII accurate, complete, and up to date. We will retain your PII for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

14. Access to PII

For other PII, we will make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to the regional privacy email addresses.

15. Cookies and Other Technologies

TCS’ services, push notifications, interactive applications, email messages, and offers sent to you by TCS’ Client may use cookies and other technologies such as pixel tags and web beacons. These technologies help TCS and its affiliates better understand your behavior and facilitate and measure the effectiveness of offers provided to you.

TCS treats information collected by cookies and other technologies as non-identifiable personal information, except where IP addresses or similar identifiers are considered PII under local law.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App and post the updated Privacy Policy on our website. Please review this policy periodically for any updates.

17. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Email: [email protected]

 

Mailing Address:

Total Communicator Solutions, Inc.

ATTN: S. Blatt
11150 Santa Monica Blvd, Suite 600
Los Angeles, CA 90025