LAST UPDATED: December 15, 2018
By providing Personal Information to us, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not provide any Personal Information to us. We reserve the right to change this Policy. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.
IgnitionOne is a member of the Network Advertising Initiative (“NAI”), which is a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. IgnitionOne complies with the 2013 NAI Codes of Conduct as well as the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (“DAA”) as well as the Digital Advertising Alliance EU (“eDAA”) and the Digital Advertising Alliance Canada (“DAAC”).
- WHAT TYPES OF INFORMATION DO WE COLLECT FROM YOU?
Personal Information is information that identifies you as an individual. In order for you to take advantage of particular opportunities provided by us (for example, to sign up to be a customer or to register for a webinar), we may require that you furnish Personal Information. We collect Personal Information from you, such as your name, postal address, telephone number, e-mail address, credit card number or other payment account number, only when you voluntarily provide it to us. Please note that some jurisdictions such as the EU define Personal Information more broadly.
Third Party Advertisers. We may use third-party advertising companies to serve ads on the Site and/or on the sites on which we advertise. Please note that these companies may use information (not including Personal Information) about your visit to the applicable site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements, these companies may place or recognize a unique cookie on your browser. In addition, we may use web beacons provided by third-party advertising companies to help manage our online advertising. These web beacons enable us to recognize a browser’s cookie when a browser visits this site and to learn which banner ads bring users to our Site. To learn more about our third-party advertising companies, cookies, and how to manage your privacy choices, please visit: http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices/ or
IP Addresses. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time(s) of such visit(s) and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites.
- HOW DO WE USE INFORMATION COLLECTED FROM YOU?
Personal Information. We may use Personal Information:
– for the purpose for which it was provided (e.g., to provide services to you and contact you regarding these services, to sign you up as a customer or partner and/or to send requested information to you).
– for billing and customer care purposes (e.g., to fulfill your purchase of services).
– to respond to your problems and comments.
– to approve and enable your participation in the Site and Site services (e.g., to permit you to subscribe to our blogs and RSS feeds, as applicable).
– to permit you to participate in a webinar.
– to permit you to request access to our client login on the Site, and use our client login and the services offered therein (e.g., permit you to review your company’s bill), as applicable.
– to inform you of products, programs, services and promotions that we believe may be of interest to you.
– to send you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.
– for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Site, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
Non-Personal Information. Because Non-Personal Information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-Personal Information, which does not personally identify you, with affiliates and other third parties, for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we do combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information hereunder as long as it is so combined.
IP Addresses. We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Site and tracking your Internet usage, including identifying your geographic location. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.
- HOW IS PERSONAL INFORMATION DISCLOSED? We may disclose Personal Information:
– to our affiliates so that they may use such Personal Information for the purposes described in this policy. IgnitionOne is the party responsible for the management of the jointly-used Personal Information.
– to our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing and other similar services to enable them to provide services. For example, we may use third party analytics services, and they may place cookies on your computer and record data about your Site usage on our behalf.
– to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
– as we believe to be appropriate: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process including where we are required to disclose an individual’s information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
In the context of an onward transfer, IgnitionOne is responsible for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Privacy Shield principles if its agent processes such personal information in a manner inconsistent with the Privacy Shield principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
- OTHER IMPORTANT NOTICES REGARDING OUR PRIVACY PRACTICES.
Security / Integrity / Purpose Limitation. We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem). We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
Opt-Out. If you no longer wish to receive marketing-related emails from us on a going-forward basis, or if you would prefer that we do not share Personal Information about you on a going-forward basis with our affiliates for our affiliates’ marketing purposes, you may opt-out of receiving such marketing-related emails or from such sharing by sending an email containing your request to email@example.com. Please specify clearly which of the following choices you are opting out of:
– Receiving marketing-related emails from us; and/or
– Allowing us to share Personal Information about you with our affiliates (including our parent and subsidiaries) for their marketing purposes.
We will endeavor to comply with your request as soon as reasonably practicable and no later than thirty (30) days after a request from an EU data subject. For your protection, we will only implement opt-out requests with respect to the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our affiliates with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related emails from such affiliates, please contact such affiliates directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
Do Not Track. A number of industry groups are attempting to develop a Do Not Track (DNT) standard. Currently, the standards regarding the DNT signals and appropriate responses are not defined. Accordingly, we do not assign a meaning to DNT signals.
Accessing, Changing or Suppressing Personal Information. If you would like to access, change, suppress or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us by sending an email containing your request to firstname.lastname@example.org. IgnitionOne acknowledges that EU and Swiss individuals have the right to access the Personal Information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to email@example.com. For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. If you’re located in the EU, scroll down to see any additional rights you may have.
In each event, you must clearly indicate the information that you wish to have changed or suppressed or clearly indicate the limitations you wish to put on our use of your Personal Information. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom.
Note Regarding the Use of the Site by Children: The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through the Site.
Special Data Protections for EU Data Subjects. As of May 25, 2018, the General Data Privacy Regulation (“GDPR”) will afford additional rights to EU data subjects. Those rights include the right to complain to EU Supervisory Authorities and the right to access, correct and delete certain personal data processed by IgnitionOne by visiting our EU data subject access request page. Moreover, with respect to EU data subjects, Personal Information includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. We process certain Personal Information provided by Clients and partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services. We collect contact details from EU data subjects via our Website with consent and ask for consent for our Website to place cookies onto EU desktops. Where consent is our legal basis for processing, we endeavor to make it just as easy to withdraw consent as it is to provide consent. Where IgnitionOne receives from an EU data subject a request to cease processing of data via one of the choice mechanisms listed above, IgnitionOne will stop all data processing with respect to the opted out browser or device unless such processing is required by law. The retention period for data from EU data subjects will be based on the specific data collected and the purpose of processing such data. IgnitionOne’s data protection officer and EU Representative is Cedric Brosens and he may be contacted at Cedric.Brosensfirstname.lastname@example.org.
IgnitionOne is subject to the investigatory and enforcement powers of the FTC.
Jurisdictional Issues. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. If you are located outside the EEA or Switzerland, by using the Site and submitting any Personal Information, you consent to the transfer of Personal Information to other countries, such as the United States, which may provide a different level of data security than in your country of residence.
470 Park Avenue South, 6th floor
New York, NY 10016
Please note that email communications will not necessarily be secure; accordingly, you should not include credit card information in your email correspondence with us.
Enforcement. We encourage interested persons to raise any concerns using the contact information provided above and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
IgnitionOne has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.