I. Changes to this Policy
Clickagy reserves the right to change or modify this Policy at any time, without prior notice, by posting the modified Policy on the Services. If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from or about you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Services or providing notice pursuant to the provision of our Services, but we make no guarantee as to such advance notice. Your continued use of the Services indicates your acceptance of any revised Policy. We encourage you to review our Policy whenever you use our Services to stay informed of ways you can protect your privacy.
II. Information Gathered
Clickagy collects information about you from various sources and methods. We collect this information for purposes including but not limited to analytics, behavioral and targeted advertising, retargeting, audience segmentation, and audience modeling. We generally collect information in three ways: (1) you voluntarily provide information to us, (2) we collect information automatically, and (3) other parties may provide information to us.
A. Information You Provide to Us
You can visit the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual (which we will refer to in this Policy collectively as “Personal Information”). We use your Personal Information to fulfill your requests for products and services, to improve our Services, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Policy.
We refer collectively to all information we collect that is not Personal Information, including Usage Data, demographic data, aggregate data, and de-identified Personal Information, as “Non-Personal Information”. We may use Non-Personal Information for any business purpose. If we combine Non-Personal Information with Personal Information, we will treat the combined information as Personal Information under this Policy.
Here are examples of the information we may collect:
- Personal and online identifiers;
- Internet activity information;
- Approximate geolocation data;
- Inferences about your predicted characteristics and preferences;
- Approximate Demographic Data. We estimate certain demographic data based on internet browsing behaviors. We do not collect declared demographic data such as specific age, declared gender, or any other form of declared demographic data
- Categories of personal information described in Cal. Civ. Code § 1798.80(e)—specifically encrypted email address
B. Information We Automatically Collect
We and our third-party service providers (including any third-party content, advertising, and analytics providers) automatically collect certain information from your device or web browser when you interact with the Services to help us understand how our users use the Services and to target advertising to you (which we will refer to in this Policy collectively as “Usage Data”). For example, each time you visit the Services, we and our third-party service providers automatically collect your location, IP address, or other unique identifier, browser and computer type, Internet service provider used, clickstream information, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on the Services.
We and our third-party service partners use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.
Below we explain the different types of cookies that may be used on the Services.
- Necessary Cookies. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Disabling these Cookies may make the services and features unavailable.
- Preference Cookies. Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region you are in.
- Session Cookies. These types of cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session cookies to support the functionality of the website and to understand your use of the site—that is, which pages you visit, which links you use and how long you stay on each page.
- Analytics Cookies. These cookies are used to collect information about traffic to our Services and how our users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
- Marketing Cookies. Marketing cookies are used to show our users display advertisements across websites such as those on Facebook, LinkedIn or general web. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
- Unclassified Cookies. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
C. Information We Receive from Others
We supplement the information we collect with outside records in order to learn more about our users, to perform behavioral and targeted advertising, and for other purposes. We receive this information about you from public sources or third parties, including without limitation businesses we affiliate with, consumer data resellers, social networks, and advertisers. We combine the information we receive from those other sources with information we collect through the Services. In those cases, we will apply this Policy to the combined information.
III. Use of Collected Information
We use the information we collect, including Personal Information and Usage Data:
- To support our legitimate interests, consistent with your rights and preferences;
- To communicate with you, respond to your requests, or provide you with updates and information;
- To better understand our users, their interests, and their preferences;
- To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;
- To develop, deliver, and improve our products, services, and other offerings, some of which may be offered in partnership with other parties;
- To manage and customize advertisements or promotional offers;
- For security purposes;
- For internal purposes such as auditing and data analysis;
- To provide services that are subject to terms you have accepted, such as enforcing our licenses, agreements, and terms of service, which may include reasonable monitoring to detect and prevent misuse or fraud;
- To the extent you give consent, such as when we would like to process your personal information for a purpose that would otherwise be incompatible with this policy.
- To comply with legal obligations.
We may share Personal Information we collect with service providers to support the Services and perform certain services on our behalf and under our instruction. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We may also share Personal Information with advertisers and other marketing partners for purposes of creating segments for advertising. Our segments include, but are not limited to audiences for Demographics, Interests, B2B, In-Market, Brands and Automotive. By going here, consumers will find a list of segments that are made available to Clickagy’s business partners by third-party data providers.
We may also use non-sensitive politically related segments to help deliver tailored advertising. For example, Clickagy customers may deliver tailored advertising regarding political affiliation because a browser previously visited websites that are focused on politically-related topics such as political news, political issues or national committees.
We may also use non-sensitive health related segments to help deliver tailored advertising. For example, Clickagy customers may deliver tailored advertising regarding health topic interest because a browser previously visited websites that are focused on health topics such as exercise, healthy diet, wellness, and symptoms research.
IV. Where Information is Processed
The Services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence.
V. Disclosure of Information Related to Law/Legal Proceedings
Clickagy reserves the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Services.
VI. Change of Control
We also reserve the right to transfer information about you to a successor organization if we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner consistent with this policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
VII. Data and Information Security
Clickagy is committed to protect the security of its users’ data and information and will take necessary steps to assure data and information security. We use a variety of industry standard security measures, including sophisticated encryption and authentication tools to maintain the safety of your Personal Information from accidental loss, unauthorized access, use or disclosure. Access to personally identifying information will be protected and controlled by password and restricted permissions. Regardless of these efforts, no data transmission over the Internet can be guaranteed to be 100% secure. The safety and security of your information also depends on you. By using the Services, you agree that Clickagy will not be liable for any third-party action, misuse, abuse or infringement of data and information security.
VIII. Data Retention
IX. Do Not Track
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites.
X. California Consumer Privacy Rights
Clickagy is committed to protecting the privacy of California residents under the California Consumer Privacy Act (CCPA). This Section provides additional details about the Personal Information Clickagy collects about California residents and the rights they have under the CCPA. When we say “Personal Information” in this Section of this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.
To find out more about the Personal Information that Clickagy has collected over the last 12 months, including the categories of sources, please see the “Information Gathered” section above. We collect this information for the business and commercial purposes described in the “Use of Collected Information” section above, including by selling personal information to our Clients and Data Partners (please see below regarding opting out of the sale of your personal information).
We may have "sold" (as that term is defined in the CCPA) Personal Information in the following categories from consumers within the last twelve (12) months. The categories below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact "sold" but reflects our good faith belief to the best of our knowledge that some of that information may have been shared for value in return. The types of personal information we have sold to our Clients and Data Partners during the preceding 12 months include identifiers (online identifier, internet protocol address, hashed email address), Internet or other electronic network activity information (information regarding your interaction with an internet website, or advertisement), and inferences drawn from this information. We will update this disclosure from time to time as appropriate.
We may use or disclose Personal Information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the types of personal information. The types of personal information we have disclosed for our business purposes during the preceding 12 months include identifiers (unique non-personal identifier or online identifier), Internet or other electronic network activity information (information regarding your interaction with an internet website, or advertisement), and inferences drawn from this information. We will update this disclosure from time to time as appropriate.
Subject to certain limitations, the CCPA provides California residents the following rights:
- Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
- Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
- Right to Opt-Out: You have the right to request that we no longer sell your Personal Information to third parties;
- Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
California residents may make a request pursuant to their “right to know”, “right to request deletion”, and/or “right to opt-out” under the CCPA by visiting our “Do Not Sell My Personal Information” page on our Website or by clicking here, by contacting us at firstname.lastname@example.org, or by calling (833) 737-1973. In order to verify your request to know or delete information, we may require you to take certain actions, such as filing in our webform here, or to provide us with certain information to be used solely for the purpose of verifying your identity.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
If you have additional questions about this Policy or how to exercise your rights under the CCPA, please contact us at email@example.com or (833) 737-1973.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties' direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.
XI. Nevada Privacy Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us in accordance with the “Contact Us” Section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your information.
XII. Children’s Privacy
Clickagy is committed to protect children’s privacy and to follow the laws, regulations and guidelines in regard to children’s privacy. Clickagy does not knowingly accept or solicit personally identifiable information from a user known to be under the age of thirteen (13). If you have concerns regarding children’s privacy, please contact us at firstname.lastname@example.org. We are committed to act promptly to answer your concerns.
XIII. Disclaimer Regarding Linked Sites
We may provide links to or embed videos hosted by third-party websites, services, and applications that are not operated or controlled by us. This Policy does not apply to third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.
XIV. Partnerships and Associations
A. Networking Advertising Initiative
The Network Advertising Initiative (NAI) is a coalition of online advertising companies committed to complying with self-regulatory standards that establish responsible business and data management practices. Clickagy is a participating member of NAI and is compliant with NAI self-regulatory principles. The NAI offers a tool to express a preference to opt-out of the receipt of tailored advertising, available here.
B. DAA Membership
Clickagy is also a participant in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising and follows the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. The DAA also provides a global opt-out feature, available here, that lets users choose not to receive cookies from companies that are DAA members.
C. IAB Europe
Clickagy participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Clickagy's identification number within the Framework is 1222.
XV. Contact Us
If you have questions about the privacy aspects of the Website or our Services or would like to make a complaint, please contact us by email at email@example.com.
Last Modified on November 7, 2023