Jornaya Privacy Notice
Last Updated: December 30, 2022
TABLE OF CONTENTS
- OUR COLLECTION AND USE OF PERSONAL INFORMATION
- DISCLOSURE OF PERSONAL INFORMATION
- THIRD-PARTY TRACKING AND ONLINE ADVERTISING
- CONTROL OVER YOUR INFORMATION
- DATA RETENTION
- CHILDREN’S PERSONAL INFORMATION
- LINKS TO THIRD-PARTY WEBSITES OR SERVICES
- UPDATES TO THIS PRIVACY NOTICE
- CONTACT US
- ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
Welcome! Lead Intelligence, Inc. d/b/a Jornaya (“Jornaya,” “we,” “us,” or “our”), a Verisk company, provides a range of data solutions and consumer analytics products designed to help both for-profit and not-profit organizations, including marketing companies and platforms and their own customers, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on our websites, are used to help marketing that occurs through direct mail, email, online, connected-TV and other marketing channels.
Your privacy is important to us. This Privacy Notice explains how Jornaya collects, uses, discloses, and otherwise processes personal information in connection with our services. This Privacy Notice does not address our privacy practices relating to Jornaya job applicants, employees and other personnel.
Our Services: When we use the term “Services”, we are referring to our Internet websites and end-to-end engagement and membership programs that we offer and manage on our own behalf, including:
- Websites, Online Services, and Jornaya Business Activities: our websites that we own and operate that link to this Privacy Notice
(“Websites”), our apps, and other activities that support the Jornaya business (such as marketing and advertising practices);
- Data Services: our data solutions and consumer analytics products.
- Platform Services: our proprietary technology platform, including any scripts or code provided by Jornaya (“Scripts”), and any products/services provided by Jornaya (collectively the “Platform”).
Jornaya is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.
Our Relationship to Customers: When our customers (“Customers”) use our Services to submit, manage, or otherwise use content relating to our Customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer, who is the “data controller”. This Privacy Notice does not apply to such processing, and we recommend you read the privacy notice of the respective customer if their processing concerns your personal information.
Our Relationship to Consumers: Jornaya provides its Services to our Customers and does not have a direct relationship with consumers (our Customers’ end users). Jornaya does not control the privacy policies of other websites or third parties that consumers may interact with, including those of our Customers. We encourage consumers to read all applicable terms and conditions, policies and/or statements of the websites consumers visit to understand their data processing practices and any rights they may have in relation to the collection, use and disclosure of their personal information.
I. OUR COLLECTION AND USE OF PERSONAL INFORMATION
a. WEBSITES, ONLINE SERVICES, AND JORNAYA BUSINESS ACTIVITIES
We collect personal information in a variety of ways. For example, you may provide us your personal information when you visit our Websites, send us a message, subscribe to our mailing list, newsletters or other forms of marketing communications, participate in a survey, redeem a promotion, or use our Services such as the Data or Platform Services. We may link or combine the information collected from you with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below).
The following sections provide more detail on the personal information collected through each of our Services, and our use of such information.
Personal Information Collected from You
- Inquiry and Communications Information, including information provided when you submit a contact or service request through one of our forms, including requests to join one of our programs, such as the Publisher Partner Program, a request made through our VIA Directory or MyJornaya, or schedule a demo. The personal information we may collect in response to a request may include name, job title, company name, corporate website, email address, and/or phone number. We may also collect any personal information you may provide in custom messages sent through the forms, in communications with through our chatbot (which is provided by a vendor), or to one of our email addresses. We use this information to review and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
- Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
- Account Information. If you sign up for our Data Service or Platform Services and create an account, we may collect information such as your email address, user ID and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.
- Newsletter and Marketing Emails, including email address. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices including updates to our terms and services).
Personal Information Collected from Third Parties
We may also combine the information we receive from you with personal information we obtain from third-party sources, including the following:
- Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers. Our service providers that perform services solely on our behalf, such as website hosting providers and certain advertising/marketing providers, collect personal information and may share some or all of this information with us.
- Information from Other Sources. We may obtain information from other sources, including through third-party information providers, our shareholders, our affiliated companies, Customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
b. DATA SERVICES
Our Data Services support a multitude of Customers both for-profit and not-profit organizations, including marketing companies and platforms and their own clients, by helping our Customers market their goods and services in a relevant and efficient way. Our solutions, many of which are described on our Websites, are used to help marketing that occurs through direct mail, email, online, connected-TV and other marketing channels. The personal information we collect in connection with our Data Services are as follows:
Personal Information Collected from Third Party Sources
When we provide our Data Services, we leverage personal information data we receive from a variety of sources, including through websites and mobile apps, public records and other publicly available sources, government entities, social networks, our Customers, consumer data resellers, and other data compilers.
The personal information we collect from the various sources may include (on the individual, household, or geographic level), such as:
- Contact information, such as your name, address, and other contact information.
- Professional information, including occupation and job title.
- Particular interests, such as (for instance) home improvement, music, online shopping, health and beauty sport, or travel, or political leanings, and the organizations to which you belong or have belonged, or to which you have contributed to.
- Demographic information, such as age, gender, level of education or likely income range.
- Publicly available information, such as that available from government information and files.
- Inferences, which may include any of the categories of personal information listed on this section – for instance, if a household is in a particularly wealthy area, we might infer a particular income range; if a person’s name is “Catherine” we might infer gender as likely female.
Our Uses of Personal Information in Connection with Our Data Services
Jornaya uses the information collected through our Data Services for various purposes, including the following:
- Data Marketing Services. Our Services include providing marketing information to our Customers, generally regarding which of their customers or prospective customers are most likely to be interested (or disinterested) in certain offers, or how to best contact or identify those customers. Similarly, we help our Customers identify and understand their customers better, by providing insights about them. Our Customers include (but are not limited to) brands and agencies and various marketing data platforms that help them to market and advertise to their own customers (and prospective customers); our Customers also include other data compilers, who work with their own customers, as well as performance marketing, lead generation and comparison-shopping website operators.
- Online Targeting. We sometimes create defined audience segments (“Audience Segments”) based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with health care professionals, or with an interest in international travel). When we do this, we may work with a data partner that “matches” our Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels. You may learn more about how to opt out of this and other online ad targeting in the Control Over Your Personal Information section of this Privacy Notice.
- Identity Products. We sometimes use the information we collect to create (or to help our customers create) “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
- Academic and Market Research. We sometimes use the information to help our customers understand specific markets and what influences the purchase decision and behavior of their target audiences.
- Location and Spatial Analysis. We sometimes use the information to help our customers better understand market opportunities at proposed physical site locations.
- Additional Marketing Services. Other Services we may sometimes provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (a) help with targeting and optimizing direct mail, email campaigns, display, social and mobile marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases, or helping customers to detect and prevent crime and fraud; or (d) providing “validation” or data hygiene services, which is how companies update and/or correct their databases by verifying or removing or correcting old, incorrect or outdated information.
- To Operate Our Services: We also use the Information for our own internal purposes – such as to improve, test, update and verify our own database; to develop new products; and to operate, analyze, improve and secure our Services and our databases and servers.
c. PLATFORM SERVICES
We have three types of Customers who access, use, and interact with our Platform Services in different ways, as follows:
- “Publishers” are companies who are accessing and using the Services to create Universal LeadiDs (as further defined below) on their own web site(s) or platform(s) (“Publisher Platforms”).
- “Queriers” are companies who generate data on their own or receive data from another party with a Universal LeadiD or other identifiers (“Identifiers”) and desire to verify and/or append certain attributes to the Identifiers by querying our network. A Querier can also be a Publisher.
- “Partners” are companies who work with Jornaya to provide supplemental services to Publishers or Queriers through our Services, either by incorporating certain aspects of our Services, or by integrating with our Services. Partners may contribute their own data or access data via APIs, SDKs, web related services. In some cases, we may use Partner pixels, cookies, scripts or tags alongside our Script.
The Platform allows our Customers to (i) verify the data’s origin and history, (ii) help advertisers, vendors and marketers analyze first, second and third-party consumer (“consumer(s)”) interactions to, for example, focus their attention and efforts on consumers who may be interested in certain products and/or services, and (iii) supplement our Services with related services provided by our strategic partners (iv) verify that a lead event was or was not TCPA Compliant to the Customers’ standards by identifying if there was active or passive consent to a TCPA disclosure.
In providing the Platform Services to our Customers, Jornaya may provide specific services in a capacity of a processor (service provider) or a controller (business) depending on the type of service, as follows:
Jornaya as a Processor (Service Provider)
- Event Data: the Platform facilitates the capture of data from unique consumer events, which includes, but is not limited to, lead age and history information, lead integrity information, Publisher’s account number, Publisher name, referrer URL, and information that website visitors/end users may submit in the open text fields of Publisher Platforms, such as name, contact information, annual income, loan amount, and other information provided in connection with the requested service (“Event Data”).
- Contributed Data: Our Customers also may provide to Jornaya additional information in their possession, such as conversion data, including the personal information of our Customers’ end users, including name and contact information, through a query or batch file (“Contributed Data”).
When you submit any information relating to consumers to us or to our service providers in connection with your use of the Platform Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
Jornaya as a Controller (Business)
In providing the Services to our Customers, we may also collect or otherwise obtain Personal Information in our capacity as a controller or business. This may include the following categories of data:
- Derived Data: Derived Data is derived from, Event Data or Contributed Data. Derived Data may be (i) related to an Event associated with a Universal LeadiD (for example, lead age, data integrity, TCPA disclosure match status, lead origin, and lead velocity); (ii) related to a consumer associated with an Identifier; or (iii) associated with any aspects of Contributed Data without exposing the Contributed Data itself (as defined above).
- Predictive Insights: We may also use the categories of information described above to make predictions about certain likely behaviors or outcomes, such as your interest in a particular product or service.
We may use this information to provide the Services to our Customers, and, in the case of Derived Data, to facilitate and enhance our other services and offerings.
Additional Uses of Personal Information
For all of our Services, we may also use the personal information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations and to deliver the Services you have requested;
- Manage our organization and its day-to-day operations;
- Verify your identity and entitlement to products or Services, when you contact us or access our Services;
- Communicate with individuals, including via email, direct mail, social media and/or telephone calls;
- For marketing and advertising purposes, including to market to you or offer you through email information and updates on products or services we think that you may be interested in;
- Identify and analyze how individuals use our Services;
- Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Comply with contractual and legal obligations and requirements;
- To fulfill any other purpose for which you provide personal information; and
- For any other lawful purpose, or other purpose that you consent to.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
Through the provision of our Services, we may process de-identified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Jornaya will maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Jornaya satisfies the requirements under applicable law.
We may also aggregate data for reporting, analytics, and other business reasons, including to promote or describe the use of our services.
II. DISCLOSURE OF PERSONAL INFORMATION
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
- Jornaya Entities: We may share personal information with other companies owned or controlled by Jornaya, and other companies owned by or under common ownership as Jornaya, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
- Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
- Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section for more information.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or marketing-related publications.
Additional Disclosures of Personal Information – Data Services
In the provision of the Data Services, Jornaya may also share personal information with Customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future). This includes also includes sharing in the following ways:
- With Our Customers: As described above, we license Personal Information in various ways to our customers (and sometimes to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends mailings for a Customer), or ad agencies that they work with.
- With Our Partners: We also may share Personal Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf.
- With Our Service Providers: We share the Personal Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s). For instance, we may share the Personal Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Personal Information), security vendors, payment vendors (as to our business-to-business information), and other companies help us deliver or develop Services.
Additional Disclosures of Personal Information – Platform Services
In the provision of the Platform Services, Jornaya may also share personal information in the following ways:
- Sharing as a Service Provider/Processor. We share personal information only as necessary to enable us to provide our Services to Queriers who wish to verify that a certain event(s) took place at the Publisher Platform in which a consumer participated. At times, consumer personal information is shared with Partners to enable us to provide certain Services to Publishers and/or Queriers. In that sense, we act as a processor or service provider under applicable privacy laws, and do not retain, use, or share any personal information for any purpose other than to provide our services as specified by our contract with our Customers.
- Derived Data. Jornaya may disclose Derived Data in its discretion as part of the Services it provides, including to third parties, business parties, or other Jornaya Customers.
- Predictive Insights Service. In order to provide certain aspects of the Services, Jornaya may use insights and use a scoring model to help predict a requested Customer outcome.
- Activate Service. Jornaya may share with its Customers information related to a particular consumer in relation to specific activities (for instance, whether a consumer visited a website that share commonality of services).
IV. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Please see Online Ads in the Control Over Your Information section below to learn how you can opt out of interest-based advertising.
We may engage in the following:
Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Twitter, LinkedIn, YouTube or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below.
V. CONTROL OVER YOUR INFORMATION
You may control your information in the following ways:
- Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices, or updates to terms and services).
- Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly. We may not be able to modify or delete your information in all circumstances.
- Further, note that restricting the use of these technologies might negatively impact an individual’s experience using our Services, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Notice. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. An individual may also have options within their email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
- Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
- Consumers: If a consumer does not want us to store his or her information, the Consumer can accomplish this by not visiting or not engaging with Publisher Platforms that utilize our Scripts or Services, or by requesting at the Publisher Platforms the consumer visits not to capture or use certain information captured during an event on the Publisher Platforms pursuant to the terms contained on such Publisher Platforms. A consumer may also have options to prevent cookie storage through their browser settings. Jornaya does not control the privacy policies of other websites or third parties consumers may interact with, including those of our Customers. We encourage consumers to read all applicable terms and conditions, policies and/or statements of the websites consumers visit to understand their data processing practices and any rights they may have in relation to the collection, use and disclosure of their personal information.
VI. DATA RETENTION
We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
VII. CHILDREN’S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
VIII. LINKS TO THIRD-PARTY WEBSITES OR SERVICES
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
IX. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify partners and Customers by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
X. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact us using one of our forms (for our data services, please click here; for our Platform Services, please click here), or send us an email to firstname.lastname@example.org.
XI. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
For residents of the States of California, Colorado, Connecticut, Nevada, Utah and Virginia: These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our services, please see the main body of this Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, the Additional Disclosures set out in this Section do not describe our practices when we process Customer Data as a service provider on behalf of our Customers in accordance with our contractual agreements with our Customers.
Your Privacy Choices
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The Right to Know. The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you in the last 12 months, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
- The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
- The Right to Control over Sensitive Information. You have the right to exercise control over our collection and processing of certain sensitive information.
- Right to Control over Automated Decision-Making/Profiling. The right to direct us not to use automated decision-making or profiling for certain purposes.
- The Right to Opt Out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to “sell” personal information we have collected about you to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
- Right to Appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
- Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
- Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
- Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
- Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
Website and Online Services
To submit a request to exercise one of the privacy rights identified above with regards to your personal information collected or otherwise processed pursuant to the Website and Online Services, please submit a request by:
- Filling out our Individual Rights Request Form; or
- Calling our toll-free number at 1-(866) 207-1399.
To submit a request to exercise one of the privacy rights identified above with regards to your personal information collected or otherwise processed pursuant to the Data Services, please submit a request by:
- Filling out our Individual Rights Request Form; or
- Calling our toll-free number at 1-(866) 207-1399.
To submit a request to exercise one of the privacy rights identified above with regards to your personal information collected or otherwise processed pursuant to the Platform Services, please submit a request by:
- Filling out our Individual Rights Request Form; or
- Calling our toll-free number at 1-(866) 207-1399.
We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising
Unless you have exercised your Right to Opt-Out, and as described in the Disclosure of Personal Information section of these U.S. Disclosures, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.
You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
To exercise the Right to Opt-Out, please fill out the applicable Individual Rights Request Form listed in the How to Exercise Your Privacy Rights section above.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the applicable privacy law) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent’s authority to act on your behalf.
For requests to know, delete, or correct personal information, we require the following for verification purposes: (a) a power of attorney valid under the laws of the state where you reside from you or your authorized agent; or (b) sufficient evidence to show that you have: (i) provided the authorized agent signed permission to act on your behalf; and (ii) verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the applicable Individual Rights Request Form listed in the How to Exercise Your Privacy Rights section above.
The following disclosures only apply to residents of the State of California.
Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, commercial information, characteristics of protected classifications under California or US law, internet/network information, geolocation data, professional/employment information and inferences, sensitive personal information as defined under California law, inferences drawn from any of the information identified above to create a consumer profile. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see How We Collect and Use Information section of our Privacy Notice.
- Sales of Personal Information and Sharing for Targeted Advertising. In the previous 12 months, we have sold or shared for targeted advertising purposes the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:
- Commercial or transactions information
- Characteristics of protected classifications under California or US law (inferenced or actual, including self-reported) E.g., race; color; religion; sex/gender; pregnancy, marital status; military or veteran status; national origin; ancestry; age (over 40) (may be inferenced, actual or self-reported)
- Internet / Network Information
- Geolocation data
- Professional or employment-related information
- Inferences data E.g., consumer information or preferences.
In addition, please see Third-Party Data Collection and Online Advertising section of the Privacy Notice to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us.
- Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Our Customers;
- Commercial recipients, which may include data compilers and consumer data resellers, consumer goods retailers and informational and retail websites, content publishers, non-profit organizations; business-to-business services and organizations, and affiliate networks;
- Advertising networks and media platforms;
- Political campaigns;
- Internet service providers;
- Data analytics providers; and
- Social media networks.
- Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at email@example.com to inform us if you, or your minor child, are under the age of 16.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at firstname.lastname@example.org We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e. you are the child’s legal guardian or authorized representative).
- “Shine the Light”. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at email@example.com
- Notice of Financial Incentives. We may offer various programs and other financial incentives that may result in differences in our prices or services offered to Customers. To obtain access to these offerings, we may collect and retain personal information. We have determined that the value of these programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering. The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information below. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Control Over Your Information section of our Privacy Notice.
Consumer Rights Metrics 2021. The following data reflects the California consumer rights requests that we have processed in the 2021 calendar year (January 2021 – December 2021):
|2021 California Consumer Rights Requests|
|a. The number of requests to know (disclosures) that the business received, complied with in whole or in part, and denied.||
|b. The number of requests to delete that the business received, complied with in whole or in part, and denied.||
|c. The number of requests to opt-out that the business received, complied with in whole or in part, and denied.||
|d. The median or mean number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out.||
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