Last Updated & Effective Date: Jul 21, 2018
Information We Collect Automatically Through the Services
In order to help provide recommendations and promoted content that is relevant to your interests, we automatically collect certain information when you access websites and mobile applications that incorporate the Services. This information reflects information about the websites you visit, the mobile applications you use, and how you interact with our Services.
Browser and Device Information: We collect information about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier, and identifiers assigned to your browser or device.
Usage Data: We collect information about the websites and mobile applications you visit that integrate our Services and about the websites that you visit immediately prior to visiting a website that integrates our Services, including the date and time your browser or device accesses such websites and the specific pages accessed.
Click Data: We collect information about the content and ads that you click on within the Services.
You may be able to customize your experience by logging in to Engage.IM through a social media service. If you do this, we will have access to certain information from that service, such as your name, profile information, likes, shares, posts, etc., in accordance with the authorization procedures determined by the social media service you use to login.
You also may be able to customize your SA experience by registering as a user directly with the SA and/or Engage.IM and selecting topics of interest to customize your experience. If you do this, we will have access to the information you provide in doing so, including your name, contact information, and any preferences or interests you select.
We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including our business partners, other advertising companies, and publicly available sources.
Cookies and Other Tracking Technologies We Use to Collect Information
We use various technologies to collect information, including cookies, web beacons, web storage, unique device identifiers, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us to tailor recommendations and promoted content to your preferences over time. For example, we may use your web browsing information to show you specific recommendations and sponsored recommendations that we think will be of particular interest to you. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services and help perform a variety of functions, including delivering cookies, counting visits, and understanding usage. For more information about cookies, and how to disable them, please see “Your Choices” below.
We use the information we collect to determine what content is most relevant to you, to disseminate recommendations and promoted content to you, and to understand, measure, and report on how users interact with the Services. We also use the information we collect from the Service to maintain and constantly improve upon the Services.
• With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of SA or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among SA and any current or future parent, subsidiary and/or affiliated company; and
• With your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share de-identified information with advertisers that partner with us to help them understand how well their advertisements performed.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of some websites.
Advertisers and publishers may provide contact information through our Site to find out more about SA, be contacted by a SA representative, or to start working with SA. SA (and its agents and service providers) may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research. We will also use the information we collect from advertisers and publishers for invoicing and billing purposes. We will not rent or sell this information to other companies. You may opt out of receiving promotional emails from SA by following the instructions in those emails or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
SA may also work with third parties that collect data on our Site and on other websites to serve you targeted ads. You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program by visiting about http://optout.aboutads.info/. If you are in the EU, you may opt out at the European Digital Advertising Alliance, http://www.youronlinechoices.eu/.
We store the information we collect for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
SA and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
When we transfer personal data from the European Union or Switzerland to the United States, we comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States, respectively.
In compliance with the Privacy Shield Principles, we are committed to resolving complaints about our processing of your personal data. EU and Swiss individuals with inquiries or complaints regarding our compliance with the Privacy Shield program should first contact us at email@example.com
We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint.
If we share personal data transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
We take reasonable measures to help protect the information we collect from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet or electronic storage can be completely secure, so we cannot guarantee the absolute security of any data.
If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to provide content and advertisements that may be of interest to you, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
• There is another applicable lawful basis under which we are permitted to process your personal data.
Data Subject Requests
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org
Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
If you have any questions or need to contact us, please do so at email@example.com