I. Connect Digital, Inc.’s Services
II. Information Collection and Use from Various Sources
A. Information Collection. Connect may receive or collect the following type of information (collectively, the “Information”) from a variety of consumer-facing companies and services, data compilers and suppliers, and marketing platforms (collectively, “Marketing Platforms”) as well as from its Clients, when it performs services for those Clients:
a) IP addresses and the location of mobile devices;
c) Personal Information (“PI”) such as first and last name, postal address, and email address, which we may, for instance, link to IP address;
d) Hashed values that are derived from PI (such as email addresses) but have been de-identified, through various means.
e) Anonymous information related to unique user behavior, such as the fact that a particular user tends to visit sports websites, entertainment websites or multifamily websites.
f) As set forth below in Section 8, we also collect certain Information on our website, that you may provide to us, or that we may collect passively. We may combine, link, or aggregate the above Information with each other. We do not, however, place PI into cookies or associate PI with cookies.
B. How We Use the Information. We may (but do not necessarily, or always) use PI and other Information we hold or collect to provide a number of marketing-related services, through online display, email and/or direct mail marketing channels. A non-exhaustive list of those types of services is as follows:
a) Targeting of Ads and Content. We use the Information to provide services to enable Clients to target “multi-channel” ads to their own customers, prospective customers, or consumers that have visited or logged in to their websites. We, our Clients or their Marketing Platforms may target ads to these customers, whether through email, display media or direct mail. In doing so, we often employ various de-identification and data segregation techniques to safeguard consumer privacy. We also may use or create “Audience Segments” that help us tailor ads and content based on a particular user’s preferences, such as an interest in sports, entertainment, or multifamily use.
b) Optimization of Ad Campaigns. We may use the Information to customize ads to a particular geographic region, or to the content of a web page on which they are shown.
c) Campaign Measurement. To measure the effectiveness of display media campaigns – for instance, to determine which types of ads are most likely to be seen or opened in what circumstances or by which types of customers, or which types of ads are most likely to lead to clicks, purchases, or other behavior.
d) Other Data Services. We sometimes use PI and other Information to provide other data services, such as (but not limited to) email and direct mail marketing services, and analytics services to help marketers understand and optimize marketing to prospects.
e) Improving Our Own Products. We may use certain PI and other Information to improve, analyze and develop our own products and services.
f) The above descriptions of our products and services are not exhaustive. We provide them to illustrate in a general way the services we offer, and how PI and other Information is used.
II. How We Respect Consumer Privacy and Choice.
a) We avoid placing PI (as opposed to a unique identifier) into cookies, and when working with data partners we generally “hash” into non-human readable, de-identified form the personal information they receive from us. In recognition of the importance of separating online data (e.g., browsing data) collected across websites from personal information, we employ other, sophisticated technical, operational and legal means to segregate databases containing PI from that data.
b) We do not work with financial or insurance account information, social security numbers, or information about individuals’ health conditions or ailments.
c) We provide multiple opt-out channels, as described below in Section III.
d) Where required by applicable legal standards, we ask our online partners to provide appropriate notice and choice to their own customers and users.
Your Opt-Out Rights. You may opt out of Our marketing platform database by going to http://www.networkadvertising.org or http://www.aboutads.info. Opting out in this manner will not prevent you from seeing ads: it will prevent targeted ads customized to what these companies believe are most likely to be relevant and of interest to you. In addition, opting out in this way (or through our opt-out cookie) is browser-specific, so if you change your browser, update it, or clear your cookie cache, you will need to opt out again.
III. How We Work With and Share the Information With Third Parties.
Connect may share Information with Clients, Marketing Platforms, and service providers that we work with or retain, in order to provide the services, we have described above (or other services we may add). More specifically:
a) Partners: We may share Information with business and data partners (including Marketing Platforms) to deliver ads and to help businesses provide more tailored advertising to you. Likewise, we may do so for analytical purposes, to measure campaigns, or inform future advertising campaigns, or to handle, analyze, or segregate the PI and other data that we handle for Clients.
b) Corporate transfers: If Connect or its significant assets are purchased by another entity, our Information will be transferred to that entity.
c) Affiliates, Parents and Subsidiaries: Connect may share some or all of the Information in our possession with affiliated or subsidiary companies.
d) As Required by Law or to Protect Any Party: Connect may disclose Information if we believe that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Connect or any other party.
IV. Cookies and Similar Technologies.
V. Information Collection and Use from Our Website.
A. Information Collected. Connect collects information from users of our website, including:
a) The domain name and IP addresses of users’ web browsers.
b) A unique identifier (such as in a cookie) that we deploy or read on your browser.
c) Aggregate information on what users’ access, utilize or visit.
d) Information, including Personal Information, that you voluntarily provided to us, such as requests for newsletters, events, and other information, and submission of contact information (such as email address) and (if you decide to accept it) credit card information.
B. Use of Information. We use the information we collect through our website to do the following:
a) Provide services to you.
b) Respond to and communicate with you (including regarding news and updates about our services).
c) Send you offers and ads for our products and services, when you browse the Site or other Sites on the Internet.
d) Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you.
e) Perform data analyses (including market research).
f) We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, services, and advertisements offered, including (but not limited to), those provided on or through the services.
g) Interest-Based Advertising and IP Targeting: We may work with data providers to serve advertising to you through display media or other methods. These providers may use personal information that we have collected or that you have provided to locate you online, such as when you visit or log in to websites or mobile applications. This information may be linked to online identiﬁers or IP addresses assigned to you and to demographic or interest-based data, in order to target you with relevant advertising, including information about our products or services. To learn more about or to opt out of this and other interest-based advertising, please visit the industry opt-out pages operated by the DAA at http://www.aboutads.info and by the NAI at http://networkadvertising.org.
h) We may use IP addresses to help diagnose problems with our servers and to administer our Site. We also may use IP addresses to help identify visitors to our Site for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our Site, how visitors navigate through the Site, and how we may tailor our Site to better meet the needs of our visitors. We also use the information for compliance with our legal obligations, policies and procedures.
a) We may share the Information with service providers who help us deliver the services you request, or we provide.
b) We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
c) We will disclose the Information (including PI) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
d) If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process.
e) Any and all information collected on this site will not be sold, rented, disclosed or loaned. Your information will be held with the utmost care and will not be used for anything other than official business.
D. Links. This web site may provide links to other Web sites that Connect thinks users will find interesting or useful. Connect is not responsible for the privacy practices of these other sites.
VI. Security and Data Integrity.
We take various steps to protect the Information we license or maintain, and to house and transmit that Information in a secure way. For instance, this may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we take these steps to ensure that this does not occur.
VII. Binding Agreement; Changes.
VIII. Questions or Concerns.
If you have questions or concerns about Our privacy efforts or data products, please contact us at: [email protected].