RADIUS NETWORKS PRIVACY POLICY

Last Updated: May 2026

I. INTRODUCTION

Technology evolves rapidly and promises great benefits to both businesses and individuals (“consumers”). As technology advances, however, so do concerns about privacy. A core value at Radius Networks is that when we deploy our Flybuy technologies, it is done in a responsible manner that respects everyone’s privacy and choices. We support applicable privacy rights and choices, including the ability to access, correct, transfer, restrict, opt-out of certain processing activities, object to, and request deletion of personal information, subject to applicable law.

We are committed to a privacy framework that is concise; transparent; intelligible; easily accessible; and written in clear and plain language. Key elements of our security and privacy policies are described in the following sections.

You can choose how you engage with Flybuy products and services, and how personal information is shared with us. More specifically, you can choose whether to share certain personal information with Flybuy products, services, or applicable third-party. It’s also important to note that Flybuy generally limits collection and processing of personal information to authorized, disclosed, and operationally necessary purposes n. If you’re unsure or need more clarification, feel free to reach out!

II. WHAT PERSONAL DATA DOES RADIUS NETWORKS COLLECT AND PROCESS?

We respect your privacy!

That’s why we ask for your permission to collect and process any personal information, only during an active transaction workflow and not continuously in the background.

With your consent, personal information is processed 1) to provide access to our sites, services, and products as well as 2) for the purposes of operational needs such as to communicate with you, particularly about any support issues; enhance security; comply with applicable laws; meet contractual agreements; and continuously make improvements to optimize your experiences with us. As you choose to access our sites, service, or products, we may ask you for the following:

Name
Contact information (email address, phone number, mailing address)
Vehicle information (model, make, color, license plate number)
Order information (order ID)
Mobile device location data (only during an active transaction)
Mobile device identifier and platform type (Android, iOS)
IP address

Flybuy services are not designed to request or process highly sensitive information, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, health-related data, etc., except where expressly required for a supported customer use case.

III. WHO IS THE ‘CONTROLLER’ AND WHO IS THE ‘PROCESSOR’?

It’s important to distinguish the two. Check out how GDPR defines them.

In general, depending on how you engage with Flybuy services, Radius Networks may act as either a controller or processor of personal information.

When you engage with us as an indirect customer, the channel in which you engage with us is the ‘controller’ (e.g., merchant, brand, other service providers) of your information and we only act as the ‘processor’ of your information. For example, when you purchase a product or service from another merchant, brand, or service provider technologies or their online store, they may send your information to us in order to fulfill the purchase you made. This means that we work closely with your channel of choice to make sure that it understands how we process and protect your information on its behalf.

IV. IS PERSONAL DATA RETAINED? IF SO, WHY AND HOW LONG?

If and when we retain any personal information, it’s for the following reasons:

To enable you to make purchases through our online store and process shipping and handling.
To enable you to create and manage a profile and/or account in order to use our sites, services, and products.
To communicate with you about the products and services you purchased.
To support your preferred channels and technologies tied to our sites, services, and products.
To support your preferred/chosen third-party applications (i.e., order fulfillment).
To improve our sites, services, and products and communicate any changes/updates.
To help solve any issues when using our sites, services, and products through internal diagnostics/analytics.
To generate de-identified and aggregated usage statistics.
To support operational needs for the cloud services, such as login security auditing.
To detect and prevent fraud.
To comply with contractual agreements, regulatory legal obligations, and/or legitimate interests.
To comply with lawful requests by public authorities.

To clarify further, Flybuy is committed to processing personal information in a responsible and privacy-conscious manner designed to minimize unnecessary privacy risks.

Personal information is not retained longer than reasonably necessary for disclosed business, operational, legal, security, and related services purposes. Applicable personally identifiable information (PII) associated with transactions is generally removed or deidentified within thirty (30) days following completion of the transaction, unless otherwise required for legal, security, fraud prevention, or operational purposes.

V. IS MY PERSONAL DATA SHARED WITH THIRD PARTY SERVICES AND PLATFORMS?

First and foremost, we do not sell any data.

We may use trusted service providers and subprocessors to support hosting, infrastructure, operational, analytics, security, and related service services. Even when we do share any information, we make sure it’s done in a safe manner. For example, usage statistics are de-identified and aggregated location data is shared with our hosted infrastructure service providers. It’s also important to note when we don’t share your information. For example, when leveraging mapping and traffic service providers, personal information is not shared. If we share any personal information with a third-party vendor to provide services, we remain liable under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, if they process such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage. Most importantly, we work with third-party services providers that are expected to maintain appropriate security and privacy safeguards consistent with applicable legal and operational requirements

VI. IS MY PERSONAL DATA TRANSFERRED INTERNATIONALLY?

Our technology is deployed worldwide and your information may be processed outside of your residential country for the same purposes stated throughout this page. Flybuy applies consistent security and privacy safeguards designed to help protect personal information regardless of geographic region. We will not transfer personal information outside of the European Union (EU) or the United Kingdom unless the recipient complies with EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF or is subject to suitable contractual safeguards (e.g., Standard Contractual Clauses) to ensure that processing is in accordance with EU, Swiss, and UK compliance laws. Please review our international compliance standards below:

Radius Networks complies with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the UK, and Switzerland to the United States. Radius Networks has certified to the Department of Commerce that it adheres to the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF shall govern. To learn more about the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/

Data is hosted within the United States.

VII. DOES RADIUS NETWORKS USE COOKIES?

We use cookies to make your interactions with our sites easier and more meaningful. For example, a session cookie may store a unique identifier for each logged-in user / account holder so that when they return to the website, they don’t have to provide the same consent or log-in again (e.g., HTML5 localStorage).

Nevertheless, it’s your choice. Use our cookie consent tool to manage your cookie preferences for our website. Outside of essential cookies, which are required for core features and operations, you can manage your preferences for functional and advertising cookies, if any, at any time.

VIII. HOW IS MY PERSONAL DATA PROTECTED?

Radius Networks partners with hosted infrastructure service providers to support Flybuy services. To help protect information processed in connection with Flybuy services, we maintain several organizational and technical security measures. Below are some examples:

Organizational security measures include physical office security controls, surveillance and alarm monitoring, workforce background screening as permitted by applicable law, employee confidentiality obligations, and joiner/mover/leaver access management procedures.

Technical security measures include single sign-on, role-based access controls, encryption in transit and at rest, firewalls, intrusion detection and monitoring, authentication controls, logging and monitoring systems, vulnerability management practices, and industry-standard secure software development lifecycle practices. Our hosted infrastructure service providers maintain industry-recognized certifications and assurance programs including ISO and SOC to support security, availability, confidentiality, and cloud data protection practices. We also maintain our own SOC certifications and related security assurance practices.

You can also help protect your personal information by maintaining accurate account information and sharing updates when necessary.

IX. HOW MUCH CONTROL DO I HAVE WHEN SHARING MY PERSONAL DATA?

Our sites, services, and products will request consent where required before you share any personal information. Even after you consent, you can change your mind at any time! Please keep in mind that declining certain data collection or processing activities (including cookies) may impact the availability or functionality of certain sites, services, or products.

As a customer preferred channel / merchant, certain information is optional and you may also choose not to provide any data when creating a Radius Networks account. When using standalone mobile applications, you and your customers have privacy options and controls around what personal information is provided to purchased Radius Networks services and products. You and your customers can control in-application prompts as well as the settings available on the device(s) being used.

As a Developer integrating Radius Networks services and/or products, you can determine the privacy options made available to your customers. You can determine what personal information, if any, is shared with the integrated services and/or products. We recommend that developers follow best practices around educating and requesting location permissions from their customers. Your customers can control how supported mobile applications collect and use location information.

And, we will honor contractual safeguards in place.

X. ARE CHILDREN ABLE TO USE RADIUS NETWORKS PRODUCTS/SERVICES?

Radius Networks is committed to protecting the privacy of children and complying with applicable laws, including the Children’s Online Privacy Protection Act (COPPA) and its anticipated updates under COPPA 2.0, as well as relevant international child data protection regulations such as the General Data Protection Regulation (GDPR) in the EU and UK GDPR. Children have the same rights described throughout this Privacy Policy page. Our products, services, and websites are not intended for use by children under the age of 13 in the United States, or under the digital age of consent in other jurisdictions (which varies by country, typically ranging from 13 to 16 years old). We do not knowingly collect, use, or disclose personal information from children under these ages without verifiable parental consent, as required by law. By using Radius Networks sites, services, or products, you represent that you are either:

Above the age of digital consent in your country of residence; or
A parent or legal guardian who has provided verifiable consent for your minor dependent to use our offerings.

If you are unsure of the applicable age of consent in your jurisdiction, we recommend consulting official government resources or referencing publicly available resources regarding age of digital consent by country. If further clarification is needed, you may contact us directly, and we will assist you in understanding your rights and obligations. If we learn that we have collected personal information from a child without proper consent, we will delete that information promptly and take appropriate steps in accordance with applicable laws.

XI. HOW OFTEN DOES RADIUS NETWORKS UPDATE ITS PRIVACY POLICY?

As privacy and data protection laws continue to evolve globally, Flybuy regularly reviews and updates its privacy and data protection practices in response to newly enacted or updated legal requirements, evolving industry standards, and operational changes. This means that our privacy policy is updated more often than regularly, on top of any scheduled audits and improvements. Changes to this page will be reflected by updating the “Last Updated” at the top of the page.

For example, when the European Union (EU) and the European Economic Area (EEA) enacted the General Data Protection Regulation (GDPR) in 2016, we became aligned with its requirements by the designated due date of May 2018. We also decided to become Data Privacy Framework certified, which is not required by any law, to better protect your data by enforcing an internationally legal mechanism for safe information transfer between the United States, EU countries, Switzerland, and the United Kingdom.

Flybuy’s Privacy Policies and related practices are designed to support applicable privacy and data protection requirements across the United States and territories, Canada, and other international jurisdictions, including but not limited to:

Canada: Personal Information Protection and Electronic Documents Act (“PIPEDA”)
Quebec: QC Law 25
Puerto Rico: Privacy and breach notification requirements
California: CA Consumer Privacy Act (“CCPA”) / CA Privacy Rights Act (“CPRA”)
Massachusetts: MA Data Security Regulations
Vermont: VT Data Broker Law
Nevada: NV Online Privacy Law
Maine: ME ISP Customer Privacy Law
New York: SHIELD Act
Virginia: VA Consumer Data Protection Act (“VCDPA”)
Colorado: CO Privacy Act (“CPA”)
Connecticut: CT Data Privacy Act (“CTDPA”)
Utah: UT Consumer Privacy Act (“UCPA”)
Washington: WA Consumer Protection Act (“WCPA”) and, where applicable, the WA My Health My data (“MHMDA”)
Iowa: IA Consumer Data Protection Act (“ICDPA”)
Indiana: IN Consumer Data Protection Act (“IDCDPA”)
Tennessee: TN Information Protection Act (“TIPA”)
Texas: TX Data Privacy and Security Act (“TDPSA”)
Florida: FL Digital Bill of Rights (“FDBR”)
Oregon: OR Consumer Privacy Act (“OCPA”)
Montana: MT Consumer Data Privacy Act (“MCDPA”)
Delaware: DE Personal Data Privacy Act (“DPDPA”)
Arkansas: AR consumer privacy and data protection requirements
New Jersey: NJ Data Privacy Act (“NJDPA”)
New Hampshire: NH Privacy Act (“NHPA”)
Kentucky: KY Consumer Data Protection Act (“KCDPA”)
Nebraska: NE Data Privacy Act (“NDPA”)
Maryland: MD Online Data Privacy Act (“MODPA”)
Minnesota: MN Consumer Data Privacy Act (“MCDPA”)
Rhode Island: RI Data Transparency and Privacy Protection Act (“RIDTPPA”)
Oklahoma: OK Computer Data Privacy Act and related privacy requirements
Alabama: AL consumer privacy requirements

XII. IS THERE ANYTHING ELSE I SHOULD KNOW?

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects on consumers.
Under certain conditions and where permitted by applicable law, individuals may have the right to pursue binding arbitration relating to unresolved privacy concerns.
We may cooperate with lawful requests from government authorities where required by applicable law, legal process, or national security obligations, if a warrant or court order is provided and to meet national security needs. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
By using our sites, services, and/or products, you acknowledge and accept the practices described in our privacy policies.
Here’s a snapshot of our consumer data request metrics:

XIII. CONTACT US

We are committed to addressing verified requests and resolving complaints about our collection or processing of your personal information.

To submit a request relating to access, correction, or deletion of personal information, please email support@radiusnetworks.com.
Send other privacy inquiries to privacy@radiusnetworks.com.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Radius Networks commits to refer unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.trustarc.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.