Last updated May 11, 2018
We have prepared this Privacy Notice to explain how, why, and when we collect data from you on our website.
Please note that this Privacy Notice only applies to data that we collect when you visit the SellPoints website at www.SellPoints.com or our Retargeter website at www.ReTargeter.com (the “Sites”). To learn what data we collect when you visit the websites of our advertiser clients, please visit the SellPoints Service Privacy Notice.
1. About SellPoints’ Services
SellPoints provides targeted advertising services for our advertiser clients (“Advertisers”). When you visit a website operated by an Advertiser or a third party site where we could serve an ad to you, we may collect some or all of the data described in our Service Privacy Notice. Our platform uses that data as well as other data described below to help Advertisers provide ads to you that are more relevant to you.
For example, if you visit an Advertiser’s website and shop for football helmets, our Platform (or another platform we work with) may later serve you with targeted ads for the Advertiser’s brand of football helmets as you browse the internet or through other channels, such as emails.
2. What data we collect and how we use it
We may collect the following categories of information on our website and use them for the purposes explained below.
- Website activity: Data about your browsing activity on our website.
- Device and browser information: Technical information about the device or browser you use to access our website. For example, your device’s IP address, and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
- Contact Information: If you choose to provide your name, email address or phone number.
- Account Information: If you open an account, we will collect your username and a password and other information to necessary to open and access your account.
- Customer Service Information: Information you may provide to customer service including survey responses.
- Financial Information: Credit card number or other payment account information. This information is collected directly by our payments processor and not stored at SellPoints.
- Third party information: We may collect additional information about you from third-party sources where we have the rights to do so.
We use this data to:
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
- To send administrative information to you, for example, information regarding our websites, services, and changes to our terms, conditions, and policies.
- To communicate with you and provide you with related customer service.
- To send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you.
- To personalize your experience on the Sites by presenting products and offers tailored to you.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (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 allow us to pursue available remedies or limit the damages that we may sustain.
- prevent potential fraud and enforce our Terms of Service.
3. Data Sharing
We may disclose information about you:
- With our service providers: Companies we contract with who help with parts of our business operations. We require that our service providers only use your information in connection with the services they perform for us.
- With your service providers: Companies under contract with, or acting on your behalf, who handle data (such as a customer lists) on your behalf.
- With our related companies
- In connection with legal proceedings: When we are under a legal obligation to do so, for example, to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of SellPoints, our Advertisers or any other third party.
- In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.
- We also share technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.
Finally, we may disclose aggregated, anonymized information to third parties.
4. Cookies and related technologies
To get more information about the individual cookies dropped by our website, please see the Adjust Ad Preferences link on the footer of our website.
5. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
- You can opt out of receiving personalized ads served by us or on our behalf by following the instructions provided or by clicking here. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.
- In some cases we may link multiple browsers or devices to you. If you opt out on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
- We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
- We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
- We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices
- Please note that when using the ad industry opt-out tools described above:
- If you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.
- If you use multiple browsers or devices you may need to execute this opt out on each browser or device.
- Other ad companies’ opt-outs may function differently than our opt-out.
- You can request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact email@example.com or firstname.lastname@example.org.
In addition, if you are located in the European Economic Area you may also have the right to access, correct or update some of the information we hold about you. You can also request that we delete your information. If you wish to exercise any of these rights, please contact us at email@example.com or firstname.lastname@example.org.
6. Data retention
Identifiable information about you is held no longer than necessary for our business purposes or to meet legal requirements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
8. International transfers
We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws. For example, if we transfer your information from the European Economic Area to a country outside it, such as the United States, we will seek to take additional steps such as entering into EU compliant data transfer agreements with the data importer where necessary.
9. Can Children Use Our Sites?
The Sites are not intended for minors under the age of 18. We do not knowingly or specifically collect information about minors under the age of 18 and believe that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Information. If you believe that we have mistakenly or unintentionally collected such information, please notify us at email@example.com, so that we may delete the information from our servers.
10. Third Party Sites?
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
11. Sensitive Information
We ask that you not send us or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
12. Changes to this Privacy Notice
Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate.
13. Contact us with questions or concerns
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at firstname.lastname@example.org, or by mail at 1198 65th Street, Suite 250 Emeryville, CA. 94608 ATTN: Privacy Officer, Legal. Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.
We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.