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Targetable Sciences, Inc PRIVACY POLICY

LAST UPDATED March 22, 2022

INTRODUCTION

We at Targetable Sciences, Inc. and our affiliated companies and subsidiaries (collectively “Targetable Sciences, Inc.” “we,” “us,” “our”) are dedicated to protecting your privacy and handling your personal information with care and respect. We’ve tried to keep it as simple as possible, but if you are not familiar with terms like cookies, IP addresses and browsers, then read about these key terms first. Your privacy matters to us so whether you are new to Targetable Sciences, Inc. or our Targetable service or a long-time user, please take a moment to know our policy and if you have any questions please contact us: privacy@targetable.com

This Privacy Policy (“Privacy Policy“ or “Policy“) applies to our websites (targetable.com, targetable.io), to the Targetable services and to any other websites or services where this Policy is posted (collectively, the “Services”). This Policy describes the ways we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") in connection with your use of the Services.

For your convenience, information relating to our use of cookies and similar technologies is set out below in our Cookie Policy. The Cookie Policy forms part of the Privacy Policy, and whenever we refer to the Privacy Policy, we are referring to the Privacy Policy incorporating the Cookies Policy.

Before registering for, installing and/or using our Services, please ensure that you have read and understood how we collect, store, process, transfer, share and use your personal information. We are the data controller of the personal information we hold about you.

We may change this Policy from time to time so please check back periodically for any changes to our Policy. When we change this Policy in a material way, we will update the last updated date above. Changes to this Policy are effective when they are posted on this page. Your use of the Services is at all times subject to the Terms of Service, which incorporate this Privacy Policy. Any terms we use in this Policy without defining them have the meaning set forth in the Terms of Service. 

If you do not agree to any o

Pf the provisions of this Privacy Policy, you should not use the Services. If you have any questions or concerns, please contact us: privacy@targetable.comERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

Information You Provide to Us:

We collect personal information that you voluntarily submit directly to us when you use our Services. This can include information you provide to us when you register for our Services, fill in an online form requesting information related to our Services, create or edit your user account, correspond with us by phone, SMS, e-mail or otherwise, respond to our questions, or use some other feature of our Services. Such information may include, but is not limited to your first and last name, mailing address, e-mail address, telephone number, birth date (in order to ensure that you are old enough to use our Services), and ZIP or postal code. In order to register for Services, you may be asked to create a display name, username, and password. We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Services. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests. In addition when legally permitted, and you have authorization to do so, you may provide personal information about your customers. 

Information We Automatically Collect from You:

There is certain personal information that we collect automatically as a result of your use of the Services. This information includes but is not limited to how you access and use the Services and information about and obtained from the Third Party Platforms and you use to access our Services as further described in this Policy.

The tables in Appendices A and B summarize the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information. We may link or combine the personal information you provide us with the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us. We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our systems, research, data analysis, improving our Services, advertising and developing new products and features. We may also share such anonymized information with others. We will store the personal information we collect about you for no longer than necessary for the purposes set out in Appendices A and B and in accordance with our legal obligations and legitimate business interests. Upon termination of the Services, we retain the right to retain a copy of such information as permitted by law.

HOW YOUR INFORMATION IS USED AND SHARED

Information you provide or that we collect automatically may be used by us, our agents, business partners, or service providers who process information on our behalf to provide, maintain and improve the Services. If you elect to receive promotional communications during your registration process, we may also use information collected from you to contact you about the Services or other products or services that may be of interest to you (including special offers and promotions), to fulfill or respond to your requests, to send service notifications, improve and personalize the Services, to conduct research and analysis, to solicit your feedback about the Services, to deliver contextual and tailored Services, to monitor usage, to provide customer support. Information we collect may be combined with information collected from other sources (e.g., business partners) so that we may further improve the Services and to offer products and services to you and to improve the relevance of the Services. You may opt-out of receiving promotional communications from us at any time by visiting www.targetable.com/editinfo and updating your communication preference settings in your account, or clicking the unsubscribe link at the bottom of the communication.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

Contact information; account information;, payment information; chat, comments and opinions; information about your access and use of the Services; Services Data; your customer information, information received from third parties; and location information may be processed for one or more of the following reasons: we need it to perform our contract; you have given us permission; the processing is in our legitimate business interests and it is not overridden by your rights; for payment processing purposes and; to comply with the law.

RECIPIENTS OF YOUR PERSONAL INFORMATION

As further set forth herein, we may share your personal information with the following (as required in accordance with the uses set out in Appendices A and B):

Service providers and advisors: We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting or providing analytic services.

Business partners: We may share information with other businesses and partners to assist us in promoting our products and services, or so that they can send you information about their own products and services, including special offers and promotions. For example, if you register with us through one of our partners, we may share the information you provide (including but not limited to your e-mail address and ZIP code) with the partner through whom you reached us. Our partners may use that information to contact you about their own products and services or for other reasons. You may opt-out of receiving promotional communications from us at any time by visiting www.targetable.com/editinfo and updating your communication preference settings in your account, or clicking the unsubscribe link at the bottom of the communication. Note that our business partners are not bound by this Policy and they may collect information about you independently of us. We are not responsible or liable for any partner’s collection or use of information about you. Please review other parties’ privacy policies and terms.

Business transaction: Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. Personal information could be one of the assets transferred to or acquired by a third party.

Law enforcement, regulators and other parties for legal reasons: We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of our Services, its users or others.

LOCATION INFORMATION

When visiting our website, we may collect mobile device information like operating system, hardware type, numbers and/or codes unique to such device, device information, the location of your device, and app usage information. We may collect and process information about your actual location. We use various technologies to determine location, including, but not limited to IP address, GPS, and other sensors for the purpose of providing and improving our Services.

STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

Security:

We have security measures in place designed to help protect your personal information under our control against accidental or unlawful destruction, loss, change or damage. Please be aware that, despite our efforts, no security measures are perfect or impenetrable, and we cannot guarantee the security of the information you provide to us. Please keep this in mind when disclosing any of your information via the Internet.

You should take reasonable steps to protect against unauthorized access to your password, computer, and web-enabled devices, among other things, by signing off after using a shared computer, inserting a password on your web-enabled device, choosing a password that nobody else knows or can easily guess, keeping your password private, and periodically changing your password. You should never share your log-in information with other. We are not responsible for any lost, stolen or compromised passwords, or for any activity on your account via unauthorized password activity.

Consent to International Transfers of your Personal Information:

Targetable Sciences, Inc. and our Services are operated in the United States and are governed by United States law. If you are a resident of the European Union or other location outside the United States, please be advised that any information you provide through the Services will be transferred to the United States or other designated locations outside of the United States for certain processing/hosting operations. By using the Services, you consent to this transfer and to the use of the information as described herein. For avoidance of doubt, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this Policy.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

Right of access. You have the right to obtain:

confirmation of whether, and where, we are processing your personal information;

information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

information about the categories of recipients with whom we may share your personal information; and

a copy of the personal information we hold about you.

Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. You can update your registration information at any time by signing in to your account at www.targetable.com/editinfo.

Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. You may request the removal of any personal data associated with your access to Targetable's platform via the following request form: https://www.targetable.com/support

Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

For businesses that have submitted information, please contact us at www.targetable.com for any requests as it relates to your information.

CHOICES AVAILABLE FOR THE USE OF YOUR INFORMATION

You can opt not to disclose some information to us, but certain information is needed to register and take advantage of some of our features. However, please be aware that changes may not be effective immediately, so you may continue to receive promotional communications for a short time. 

Emails from our business partners are not bound by this Policy and they may collect information about you independently of us. We are not responsible or liable for any partner’s collection or use of information about you. Please review other parties’ privacy policies and terms.

You may unregister/delete your account at any time by submitting a request to privacy@targetable.com.  We may require additional information from you to verify your account prior to deletion.

YOUR CALIFORNIA PRIVACY RIGHTS

California law permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please send an email to legal@targetable.com 

THIRD-PARTY SITES OR SERVICES

The Services may include links to other sites. By clicking link, you may be directed to third-party sites or services. These third-parties may collect information from and about you. These third-parties are not covered by this Policy, and we are not responsible for their privacy practices, the content of their sites, or their products or services. These third parties may have their own privacy policies, terms or statements and we encourage you to learn their practices before providing information. We may also use third parties to monitor certain parts of the Services for the purpose of reporting website traffic, statistics, advertisement click-throughs or other activities. Furthermore, if you choose to log in, access or otherwise connect to the Services, or contact us, through a social networking services (e.g., Facebook), we may collect your user ID and username associated with that social networking service, as well as any information you make public using that social networking service. We may also collect information you have authorized the social networking service to share with us.

CHILDREN UNDER 18

The Services are not intended for those under 18 years of age. If you are under 18, you may not, under any circumstances or for any reason, use the Services. We do not knowingly collect personal information from anyone under 18 through any of our Services. If we become aware that we have inadvertently received personal information from someone under the age of 18, we will take reasonable steps to delete such information.

COOKIE POLICY

This Cookie Policy forms part of our Privacy Policy and should be read together with it. Cookies are small files stored on your computer or mobile device to record information on your activity. Cookies are sent to your browser from a website and stored on your device. 

Like most companies, when you interact with our Services, we and our service providers may use cookies and other tracking technologies for storing information, including pixels (also known as a “web beacon” or “clear GIFs”), local storage, and device identifiers, to help provide, protect, and improve our Services. For example, to save your preferences, personalize content, target ads based on your interests, combat fraud and abuse, and streamline the functioning of and your access to our Service.

This policy explains how and why we use these technologies and the choices you have. We use “cookies” and “similar technologies” interchangeably to refer to all of these technologies.

Cookies can be “persistent”, “session” or “security” cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. Security cookies are used for security purposes.

SIMILAR TECHNOLOGIES

We use other data collecting technologies with similar functionality as cookies, including pixels, local storage, and device identifiers. While the specific names and types of cookies we use may change from time to time as we improve and update our Services, we have provided some basic definitions in order to help you better understand our Cookie Policy.

Pixels - A pixel is a small amount of code on a web page or in an email notification that typically work in conjunction with cookies to identify our users and record user behavior. As many services do, we use pixels to learn whether you’ve interacted with certain web or email content. This helps us measure and improve our services and personalize your experience.

Local Storage - Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. We use local storage, including HTML5, to customize what we show you based on your content consumption and other past interactions with this website.

Device Identifiers - We also use mobile device identifiers for the same purposes articulated in this Cookie Policy, for example to recognize your device when you return to using our Services.

Software Development Kits - We may use third parties including our service providers and business partners who use mobile SDKs to collect information to recognize your device when you return to using our Services. We may use this technology, for instance, to analyze how you interact with our websites and to enable analytics or other features through mobile devices.

HOW WE USE COOKIES

While we use cookies to deliver, measure, and improve our Services in various ways, the cookies we use generally fall into one of the following categories:

Operational - These cookies are necessary to allow us to operate our Services as you have requested. For example, they let us authenticate your account and recognize things about you and your business so we can provide you with the Services you requested.

Security/Abuse - These cookies enable and support our security features, and help us detect malicious or unauthorized activity. We also use cookies to combat activity that violates our policies or otherwise degrades our ability to provide our Services. Cookies also help us fight spam and phishing attacks.

Functional/Preferences - These cookies let us operate certain functions of our Services in line with the choices you make. These cookies enable us to remember you in-between visits. For example, when you continue to use or come back to our Services, we will remember your settings. Deletion of these types of cookies may result in limited functionality of our Services.

Performance/Analytics - We use these cookies to monitor and assess how our Services are performing and where it can be improved.

Personalization - These cookies use information about your use of our Services, so we can provide Services that are more relevant and effective based on criteria like your profile and activity. We may also use these cookies to improve reporting on campaign performance and to determine how many times people who click on ads end up taking an action.

Marketing - We also work with third party business partners (as further explained below), such as Google, to track user activity and market our Services by showing you personalized ads for Targetable Services on third party websites and applications.

THIRD PARTY COOKIES, ADVERTISING AND DO-NOT-TRACK

Online Analytics Providers:

To help us better understand your use of the Services, we may use third-party analytics on our Services, such as those of Google Analytics. These third parties use cookies, web beacons and similar technologies to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the applicable technologies will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services and share that information with us. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Advertising Technology Providers:

Data about your activities on our Services may be collected by us or by advertising technology providers for use in delivering advertising (both online and offline) tailored to your individual characteristics, activities, interests and other factors. These ad services may track your online activities over time by collecting information through automated means, including through the use of the automated technologies described above, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you when you are using the Services and/or when you are using other websites or online services. We and third-party vendors may use first-party cookies and third-party cookies together, and other automated technologies, and in some cases additional information, (i) to inform, optimize, and serve ads based on past visits to our Services or other factors and (ii) to report how ad impressions, other uses of advertising services, and interactions with these ad impressions and ad services are related to visits to our Site or other factors.

Advertising Technology Providers:

Data about your activities on our Services may be collected by us or by advertising technology providers for use in delivering advertising (both online and offline) tailored to your individual characteristics, activities, interests and other factors. These ad services may track your online activities over time by collecting information through automated means, including through the use of the automated technologies described above, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you when you are using the Services and/or when you are using other websites or online services. We and third-party vendors may use first-party cookies and third-party cookies together, and other automated technologies, and in some cases additional information, (i) to inform, optimize, and serve ads based on past visits to our Services or other factors and (ii) to report how ad impressions, other uses of advertising services, and interactions with these ad impressions and ad services are related to visits to our Site or other factors.

You may visit the Network Advertising Initiative’s Consumer Opt-Out page or the Digital Advertising Alliance’s Consumer Opt-Out page to opt out of receiving tailored advertising based on your Internet browsing activities from companies that participate in those programs. We do not control these opt-out mechanisms. Some of our advertising-related activities may involve the services of companies that do not participate in those programs. The opt-outs apply only to the browser in which you set them. For example, if you set the opt-out while using Firefox, but then use Chrome, the opt-out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt-out process when using Chrome.

The opt-outs described in this Cookie Policy do not block or delete cookies, or prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be delivered based on other factors, such as the content of the web page in which they are shown, or demographic information obtained through other means.

When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements.

Do Not Track Disclosure:

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on the Services for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Analytics. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. 

QUESTIONS OR COMPLAINTS? CONTACT US

legal@targetable.com
Subject: Terms of Service

APPENDIX A – PERSONAL INFORMATION COLLECTED BY US FROM YOU

 

CATEGORY OF PERSONAL INFORMATION

HOW WE MAY USE IT

LEGAL BASIS FOR THE PROCESSING

Contact information,  such as your name, date of birth, phone number, address and e-mail address.

We may use this information for account registration and authentication.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We may use this information to communicate with you, including sending service-related communications, such as notifying you when you have won a contest/promotion.

We use this information to deal with enquiries and complaints made by or about you relating to the Services.

The processing is necessary for our legitimate interests, namely administering the Services, and for communicating with you effectively to respond to your queries or complaints.

Account information, such as your username, profile picture and other users you have invited to use our Services.

We use this information to operate, maintain and provide to you the features and functionality of the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to promote our Services, such as inviting new users to our Services or tagging you in comments on our social media pages.

The processing is necessary for our legitimate interests, namely promoting our Services.

Payment Information, such as your card type, last four digits of payment card number, image of your signature (if you request an email receipt)

We use this information to operate, maintain and provide to you the features and functionality of the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

Tax number or other government identifier. We may collect numbers assigned to you by tax authorities in your jurisdiction, such as your social security number or EIN.

We use this information to comply with our reporting obligations to tax authorities in the event that you win a prize while using our Service.

The processing is necessary for your legitimate interests, namely compliance with your legal obligations to report winnings to tax authorities.

Chat, comments and opinions.  When you contact us directly, e.g. by email, phone, or when you participate in a chat on our Services, we will record your comments and opinions.

We use this information to operate, maintain and provide to you the features and functionality of the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to address your questions, issues and concerns.

The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We use this information to develop new products and features available through our Services or otherwise improve our Services.

The processing is necessary for our legitimate interests, namely developing and improving our Services.

Information about your use of our Services, such as the number of ad campaigns you have participated in, the responses and interactions with those campaigns and our Service and other actions and outcomes related to the advertisement and your uses and performance of our Service.

We use this information to operate, maintain and provide to you the features and functionality of the Services, including paying you any prize money you may win when you use the Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to develop new products and features available through our Services or otherwise improve our Services.

The processing is necessary for our legitimate interests, namely developing and improving our Services or certain features of our Services.

Customer contacts. Where you give us permission, we may collect the phone numbers and names of your customers that you provide to us.

We use this information to connect you with people who have interacted with our Service or responded to campaigns, and to allow you to take actions based on their interactions.

We will only process this information to the extent you have given us consent to do so.

Information received from third parties, such as social networks. If you connect a social network to our Services, or interact with our Services through a social network, we may receive information from the social network, such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.

We use this information to improve our Service and to promote our Service.

The processing is necessary for our legitimate interests, namely promoting our Services.

Approximate Location Information. When you use certain functionalities of the Services, we may ask you to provide your precise location.

We use this information to provide you certain functionalities of the Services, such as the ability to interact with our Services at locations that subscribe to our Services.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

 

We will only process this information to the extent you have given us consent to do so.

 

All personal information set out above.

We will use all the personal information you provide us in order to operate, maintain and provide to you the features and functionality of the Services, to communicate with you, to monitor and improve our Services and business, and to help us develop new products and Services.

The processing is necessary for our legitimate interests, namely to administer and improve the Services.

 

 

 

 

 

 

 

 

 

 

ANNEX 2 – PERSONAL INFORMATION WE COLLECT AUTOMATICALLY

 

CATEGORY OF PERSONAL INFORMATION

HOW WE USE IT

LEGAL BASIS FOR THE PROCESSING

Information about how you access and use the Services . For example, Services Data, and also the website from which you came and the website to which you are going when you leave our website, how frequently you access the Services, the time you access our Services and how long you use it for, the approximate location that you access the Services from, whether you access the Services from multiple devices, how your customers react to ads and what actions they take and other actions you and your customers take on the Services.

We use information about how you use and connect to our Services to present our Services to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Services to the user.

 

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to determine products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Services and to improve our Services generally.

Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Services through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

We use information about how you use and connect to our Services to present our Services to you on your device.

The processing is necessary for our legitimate interests, namely to tailor and administer the Services to the user.

We use this information to determine products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Services and to improve our Services generally.