1. Our Collection of your Information
The information we collect may include your personal data, such as your name, contact information, IP addresses, product and service selections and other data that may identify you. We collect personal data about you at several different points, including but not limited to the following:
2. Information Collected Automatically or From Others
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. Our Services, such as those related to location data management, may collect precise geolocation information in accordance with applicable law.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. Unless contrary to applicable law or contractual agreement, we may combine your information with information that other people provide when they use our Services, including, when the option is available, information about you when they tag you.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
3. Legal Basis for Processing your Personal Data (EEA, UK and Switzerland only) With respect to personal data of individuals from the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. Our Company will generally collect personal data from you or a third party only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).
4. Our Use of your Personal Data
Our Company may use information that we collect about you to:
Fulfil our contract with you and provide you with our Services, such as:
Analyze and improve our Services pursuant to our legitimate interest, such as:
Provide you with additional content and Services, such as:
Use De-identified and Aggregated Information. We may use personal data and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to process this data. Our customers control the personal data in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.
5. Our Disclosure of your Personal Data to Third Parties
Below is a list of categories of personal data (from the California Consumer Privacy Act) we have collected and disclosed about consumers for a business purpose in the past 12 months:
Category A: Identifiers;
Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
Category F: Internet or other electronic network activity.
The above list does not include information about personal data collected and disclosed while operating as a service provider to our customers.
We have not sold consumers’ personal information in the preceding 12 months.
Please note that these third parties may be in other countries where the laws on processing personal data may be less stringent than in your country.
Potential for Other Users to Contact You
To the extent that a given application supports personal messaging functionality between and among end users, you may receive personal messages from other end users. You can disable this functionality by using the unsubscribe and other disabling instructions in the given application.
6. Our Security Measures to Protect your Personal Data
Our Company uses industry-standard technologies when transferring and receiving data exchanged between our Company and other companies to help ensure its security. This site has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access. However, “perfect security” does not exist on the Internet. Also, if this website contains links to other sites, our Company is not responsible for the security practices or the content of such sites.
7. Our Use of Automatic Collection Technologies
8. Limiting Use, Disclosure, Retention
Whenever applicable, our Company identifies the purposes for which the information is being collected before or at the time of collection. The collection of your personal data will be limited to that which is needed for the purposes identified by our Company. Unless you consent, or we are required by law, we will only use the personal data for the purposes for which it was collected. If our Company will be processing your personal data for another purpose later on, our Company will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose. We will keep your personal data only as long as required to serve those purposes. We will also retain and use your personal data for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. International Transfers of your Personal data
We are a global company. Information about you may be stored and processed in the European Economic Area, the United States or any other country in which our Company or agents or contractors maintain facilities, and by accessing our websites and using our mobile apps, software and services, you consent to the transfer of your information outside of your country. Such countries may have laws which are different, and potentially not as protective as the laws of your own country.
Whenever we share personal data originating in the EEA, the UK or Switzerland, we will rely on lawful measures to transfer that data, such as the Privacy Shield or the EU standard contractual clauses. If you reside in the EEA, UK or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data to the United States and other jurisdictions in which we operate. By providing your personal data, you consent to any transfer and processing in accordance with this Policy.
10. Accuracy of Personal data
We do our best to ensure that the personal data we hold and use is accurate. We rely on the customers we do business with to disclose to us all relevant information and to inform us of any changes.
11. Your Access to and Updating of your Personal data
Reasonable access to your personal data may be provided upon request made to our Company at the contact information provided below. If access cannot be provided within that time frame, our Company will provide the requesting party a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied. We may charge a reasonable fee in advance for copying and sending the information requested.
If you would like us to delete any personal data held about you, we will do so on request unless we need to hold the information as part of the provision of products and services to you.
12. Your Choices
We offer those who provide personal data a means to choose how we use the information provided. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal data regarding your activities on our Services and for other legal purposes as described above.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http:// www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
13. Your Privacy Rights
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws, including:
If you would like to exercise any of the above rights, please contact our support team or contact our Data Protection Officer (see our contact details in the “Contacting Us” Section below). We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
14. Additional California Privacy Rights (United States only)
If you are a California resident, the California Consumer Privacy Act may entitle you to certain rights under Section 13 in addition to the disclosures about data collection, use and sharing contained herein. Also, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of personal data to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by sending an email to firstname.lastname@example.org.
Our site, products, and services are not intended to appeal to minors. However, if you are a California resident under the age of 18, and a registered user of our Site or Service, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to email@example.com. We will process your request in compliance with applicable law.
Under California law, California residents who have an established business relationship with us may opt-out of our disclosing personal data about them to third parties for their marketing purposes.
15. Notice to End Users
Most of our services are intended for use by organizations. Where the services are made available to you through an organization (e.g. your employer), that organization is the administrator of the services and is responsible for the accounts and/or service over which it has control. Please direct your data privacy questions to your administrator, as your use of the services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this policy. Administrators may be able to:
Please contact your organization or refer to your administrator’s organizational policies for more information.
16. Children’s Privacy
Because of the nature of our business, our services are not designed to appeal to minors. We do not knowingly attempt to solicit or receive any information from anyone under the age of 17 (or other age as required by local law). If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us immediately. If we learn that we have collected any personal data in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
18. Contacting Us
Optimizer StreetCo Inc.
Data Protection Officer
401 Congress Avenue, Suite 2650
Austin Texas 78701 USA
Last Updated: March 01, 2021