Privacy Policy

This Privacy Policy describes how RedSky Strategic Protection Group ("RedSky," "we," "us," or "our") collects, uses, discloses, and protects personal data through the RedSky website, the RedSky Protection Portal, and any other RedSky online service that links to this Privacy Policy (collectively, the "Services").

1. Scope of This Privacy Policy

This Privacy Policy applies to personal data that RedSky processes through the Services in its own capacity and to personal data that RedSky processes for a church or other organizational client ("Client").

RedSky acts as a controller when it determines the purpose and means of processing, including for website operations, account administration, billing, support, security, and RedSky’s own business operations.

When a Client submits or manages data for its own safety, screening, benevolence, personnel, volunteer, or administrative purposes, that Client ordinarily determines the purpose and means of processing, and RedSky acts as a processor on the Client’s behalf.

If RedSky receives a privacy request concerning Client-controlled data, RedSky may direct the requester to the responsible Client and will assist the Client as required by applicable law and the applicable service agreement.

This Privacy Policy does not govern a third-party website or platform that provides its own privacy notice, including the separate background-screening platform operated by Armstrong Investigation Services LLC d/b/a AIS Backgrounds ("AIS Backgrounds").

2. Categories of Personal Data We Process

Identifiers and Contact Data

RedSky may process a person’s name, email address, telephone number, mailing address, date of birth, organization, title, and related contact details.

Client Account and Billing Data

RedSky may process a Client administrator’s organization, role, contact information, account credentials, permissions, subscription information, service selections, billing contacts, invoices, payment status, and limited transaction information.

Payment card or bank account information may be collected directly by RedSky’s payment processor rather than by RedSky.

Government-Identification and Screening Data

Depending on the service configuration, RedSky, AIS Backgrounds, or both may process a driver’s license number or other government identifier, identity-verification information, screening-request information, criminal or background history, screening status, and screening-result information.

The separate AIS Backgrounds platform may collect additional information under its own privacy notice, authorizations, and procedures.

Benevolence-Registry Data

RedSky may process information about a person requesting aid, including the person’s name, contact information, passed to RedSky by their Client from which the person has requested aid, and the person’s aid-request history.

Persons of Interest and Safety Data

Clients may submit names, contact information, descriptions, photographs, incident information, registry entries, supporting documents, and other records concerning a person identified for a legitimate Client-safety purpose.

Website, Device, and Usage Data

RedSky and its service providers may process Internet Protocol addresses, browser and device information, cookie or similar identifiers, pages viewed, links selected, referring pages, approximate location derived from an Internet Protocol address, security logs, and other information concerning use of the Services.

Communications

RedSky may process messages, inquiries, support requests, feedback, and other information a person sends to RedSky.

3. Sources of Personal Data

RedSky may obtain personal data directly from the person to whom it relates; from it’s Clients; from AIS Backgrounds, Image-I-Nation/FRS, and other screening or data providers; from payment, hosting, platform, analytics, security, and communications providers; from a person’s use of the Services; and from public or governmental sources when permitted by law.

4. Purposes for Processing Personal Data

RedSky processes personal data to provide, configure, administer, support, and secure the Services; create and manage authorized administrator accounts; coordinate lawful background-screening services; provide screening status, results, or registry matches to the requesting Client; help Clients manage benevolence-request history; provide safety, training, and account features; process subscriptions, invoices, and payments; communicate about the Services; respond to questions and privacy requests; prevent unauthorized access, misuse, fraud, harassment, and unlawful activity; comply with legal obligations and lawful process; establish, exercise, or defend legal claims; enforce contracts and policies; maintain business records; and develop, improve, test, and troubleshoot the Services in a manner consistent with applicable law and reasonable user expectations.

RedSky limits its collection of personal data to information that is adequate, relevant, and reasonably necessary for the disclosed purposes.

RedSky will not process personal data for a new purpose that is neither reasonably necessary to nor compatible with a disclosed purpose unless RedSky first provides any notice and obtains any consent required by law.

5. Categories of Personal Data Disclosed and Categories of Recipients

RedSky may disclose identifiers, contact data, government identification data, screening request information, criminal or background information, screening status or results, persons-of-interest information, benevolence request information, Client account data, billing data, user-submitted content, technical data, and communications as described below.

Requesting Client

RedSky or AIS Backgrounds may provide the requesting Client, screening status, registry match, benevolence-request information, persons-of-interest information, or other information requested through the contracted Services.

Consumer Reporting Agencies and Screening Providers

RedSky may disclose identifiers, government identification data, and screening request information to AIS Backgrounds, Image-I-Nation/FRS, and other background-data providers as needed to perform lawful screening services.

Payment Processors

RedSky may disclose billing and transaction information needed to process a subscription, credit-card payment, automated-clearing-house payment, refund, or related transaction.

Hosting, Platform, and Technology Providers

RedSky may disclose the categories of data reasonably necessary for providers of hosting, data storage, software development, authentication, security, communications, analytics, support, and similar business services to perform services for RedSky.

Professional Advisors

RedSky may disclose relevant information to attorneys, accountants, auditors, insurers, and other professional advisors subject to appropriate duties of confidentiality.

Authorities, Safety Recipients, and Legal Parties

RedSky may disclose information when reasonably necessary to comply with law or lawful process; protect a person’s life or physical safety; investigate or respond to a security incident, fraud, harassment, or unlawful activity; or establish, exercise, or defend legal claims.

Business-Transaction Recipients

RedSky may disclose information in connection with an actual or proposed financing, merger, acquisition, reorganization, or sale of business assets, subject to appropriate confidentiality and legal protections.

RedSky requires processors to handle personal data under written instructions and appropriate confidentiality, security, deletion or return, assessment, assistance, and subprocessor obligations when required by law.

6. Background Screening and AIS Backgrounds

AIS Backgrounds performs the background-screening services offered through the RedSky relationship and operates the platform used to initiate screening requests and receive results.

When an authorized Client administrator selects the background-screening function in the RedSky Protection Portal, the administrator may be directed to the AIS Backgrounds platform.

AIS Backgrounds and its screening providers may collect personal data directly and are responsible for their own privacy notices, authorizations, Fair Credit Reporting Act obligations, dispute procedures, and other duties applicable to consumer reporting agencies.

Depending on the service configuration, RedSky may process information needed to coordinate a screening and may receive administrative status or result information for the requesting Client.

A request to dispute the accuracy or completeness of a consumer report should be submitted to the consumer reporting agency identified in the report, pre-adverse-action notice, final adverse-action notice, or other screening communication.

The rights described in this Privacy Policy do not replace rights or procedures available under the Fair Credit Reporting Act or another consumer-reporting law.

7. Sensitive and Highly Sensitive Data

Some information processed through the Services may constitute sensitive data under applicable law, including information that reveals religious beliefs, citizenship or immigration status, or personal data concerning a known child.

RedSky also treats government identifiers, criminal and background information, persons-of-interest records, and benevolence records as highly sensitive, even when a particular law uses a narrower definition of sensitive data.

When RedSky acts as a controller, RedSky will not process sensitive data without any separate, specific, informed, and affirmative consent required by law.

When RedSky acts as a processor, the responsible Client determines the purpose and means of processing and is responsible for obtaining required notices, authorizations, and consents; RedSky processes the data under the Client’s instructions and the applicable service agreement.

Acceptance of this Privacy Policy does not, by itself, constitute consent to process sensitive data when separate consent is required.

RedSky does not collect precise geolocation data, biometric data, or genetic data through the RedSky Protection Portal.

8. Sale, Targeted Advertising, and Profiling

RedSky does not sell personal data for money or other valuable consideration, including sensitive personal data or biometric data.

RedSky does not process personal data for targeted advertising based on a person’s activities over time and across nonaffiliated websites or applications.

RedSky does not use solely automated profiling to make a decision that provides or denies employment opportunities or access to basic necessities.

Clients make their own staff, volunteer, screening, and benevolence-aid decisions, and RedSky provides tools and information to support those decisions.

9. Cookies and Similar Technologies

RedSky and its service providers may use cookies and similar technologies to operate and secure the Services, remember settings, understand traffic and usage, measure performance, prevent abuse, and improve the Services.

These technologies may collect an Internet Protocol address, browser and device information, pages viewed, interactions, referring pages, approximate location derived from an Internet Protocol address, and cookie or similar identifiers.

RedSky does not use personal data collected through these technologies for targeted advertising.

Where available, a person may use the website’s cookie controls to decline nonessential cookies, and browser settings may also block or delete cookies.

Blocking some cookies may affect website functionality.

10. Data Retention and Security

RedSky retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining security and audit records, meeting contractual commitments, resolving disputes, and complying with legal, tax, accounting, insurance, litigation-hold, and regulatory requirements.

Retention periods vary according to the type of data, the service involved, the responsible Client’s instructions, and applicable law.

When personal data is no longer required, RedSky will delete, deidentify, or securely dispose of it in accordance with applicable requirements and operational backup cycles.

Consumer reports and screening records may be subject to separate retention and disposal requirements administered by AIS Backgrounds or the requesting Client.

RedSky maintains reasonable administrative, technical, and physical safeguards appropriate to the volume and nature of the personal data processed.

Safeguards may include encryption in transit and at rest, authentication, role-based access controls, permission management, security logging, backup and recovery measures, vendor oversight, and periodic security review.

11. Deidentified and Aggregated Data

RedSky may create or use deidentified or aggregated data for security, analytics, service improvement, research, reporting, and other lawful business purposes.

RedSky publicly commits to maintaining deidentified data without attempting to reidentify it, will take reasonable measures to prevent the data from being associated with an individual, and will contractually require recipients of deidentified data to comply with applicable restrictions.

12. Consumer Privacy Rights

Subject to applicable exceptions, a Texas resident acting in an individual or household context may exercise the rights described below.

Access

A consumer may request confirmation of whether RedSky is processing the consumer’s personal data and access to that data.

Correction

A consumer may request correction of inaccuracies in the consumer’s personal data, taking into account the nature of the data and the purposes for processing it.

Deletion

A consumer may request deletion of personal data provided by or obtained about the consumer.

Portability

A consumer may request a copy of personal data previously provided to RedSky in a portable and, to the extent technically feasible, readily usable digital format.

Opt Out

A consumer may opt out of processing for targeted advertising, the sale of personal data, or profiling in furtherance of a decision by RedSky that produces a legal or similarly significant effect.

RedSky does not currently sell personal data, use personal data for targeted advertising, or make such decisions through solely automated profiling, but a consumer may still submit an opt-out request, and RedSky will respond as required by law.

RedSky will not discriminate or retaliate against a consumer for exercising an applicable privacy right.

13. Privacy Requests, Authentication, and Appeals

A person may submit a privacy request using either method below.

Email

Send an email to info@redskyprotection.com with the subject line "Privacy Request" and identify the right the person wishes to exercise.

Online Form

Use the contact form at https://www.redskyprotection.com/#contact and begin the message with "Privacy Request."

Authentication

A person is not required to create a new account to submit a privacy request, although RedSky may require the use of an existing account when reasonably appropriate to authenticate a request concerning that account.

Do not send a Social Security number, driver’s-license number, copy of a government-identification document, full consumer report, financial-account number, or other highly sensitive information in the initial email or web-form submission.

If additional information is reasonably necessary to authenticate the requester or locate the relevant records, RedSky will provide instructions for a more secure exchange.

An authorized agent may submit an opt-out request on a consumer’s behalf when permitted by law, and RedSky may use commercially reasonable methods to verify the consumer’s identity and the agent’s authority.

Response Time and Fees

RedSky will respond to an authenticated Texas privacy request without undue delay and not later than 45 days after receiving it.

When reasonably necessary because of the complexity or number of requests, RedSky may extend the response period once by an additional 45 days and will notify the requester of the extension and reason within the initial response period.

RedSky will provide required responses free of charge at least twice annually per consumer, although RedSky may charge a reasonable administrative fee or decline to act when a request is manifestly unfounded, excessive, or repetitive as permitted by law.

If RedSky cannot authenticate a request using commercially reasonable efforts, RedSky may ask for additional information and may decline to act if the request remains unauthenticated.

Appeals

If RedSky declines a request, RedSky will provide the justification and instructions for appealing the decision.

To appeal, send an email to info@redskyprotection.com with the subject line "Privacy Appeal" or use the online contact form and begin the message with "Privacy Appeal."

RedSky will provide a written decision on the appeal no later than 60 days after receiving the appeal.

If RedSky denies an appeal, the response will explain the decision and provide information about submitting a complaint through the Texas Attorney General’s privacy complaint form.

14. Exceptions and Other Rights

The rights described in this Privacy Policy do not apply to every person or every category of data.

Texas law contains exceptions for certain Fair Credit Reporting Act-regulated activity, employment-context data, business-to-business activity, and other information or processing.

The responsible Client may control data submitted through the Services, and a request concerning that data may need to be directed to the Client.

Residents of other states may have similar or additional rights under applicable law and may use the same request methods described in this Privacy Policy.

15. United States Services and Children

The Services are offered for use in the United States, and personal data may be processed and stored in the United States.

RedSky Protection Portal accounts are limited to Client’s authorized administrators who are at least 18 years old.

The current Services are not directed to children under 13, and RedSky does not knowingly permit a child under 13 to create a RedSky Protection Portal account.

If RedSky introduces a service that directly collects personal data from a known child under 13, RedSky will provide any required child-specific notice and obtain verifiable parental or guardian consent before processing the child’s personal data.

A parent or legal guardian may exercise applicable privacy rights on behalf of a known child.

16. Changes to This Privacy Policy

RedSky may update this Privacy Policy to reflect changes in the Services, data practices, vendors, or applicable law.

RedSky will post the updated Privacy Policy, revise the effective date, and provide any additional notice or obtain any consent required for a material change.

17. Contact Information

Privacy Contact: Rodney Armstrong

Email: info@redskyprotection.com

Online: https://www.redskyprotection.com/

Telephone: 832-789-1819