Last updated: January 1, 2020
1. Collection of Information and Your Privacy Rights
What information we collect and how we collect it.
1.1. User Information; Use of Services. We collect information from you when you voluntarily provide it to us or access or use our Services (“User Information”). We collect information such as (i) your computer or device (such as mobile phone or tablet) identifier, capabilities, and operating system, (ii) browser identifier, (iii) how you use the Services, (iv) your IP address, (vi) anonymous advertising identifiers, and (vii) mobile or Internet carrier. The information collected within the last twelve (12) months includes:
Category of Information
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes|
|Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code.||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card, or any other financial information, medical information, or health insurance information.||No|
|Characteristics of protected classifications under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran military status, genetic information (including familial genetic information).||No|
|Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|Biometric information||An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be use, singly or in combination with each other or with other identifying data, to establish individual identity, including but not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.||No|
|Internet or other electronic network activity information||Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, advertisement.|
|Geolocation data||Physical location, position, and movement data.||No|
|Sensory information||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|Professional or employment-related information||Present and past employment data.|
|Education information||Education records maintained by educational institutions or third parties on behalf of these institutions.||No|
|Inferences drawn from any other information||Data reflecting a consumer’s preferences, characteristics, habits, attitudes, predispositions, intelligences, and abilities.||Yes|
The categories of information described above are collected from the following categories of sources:
- Directly from you or your agents, such as through your submissions to the Services.
- Directly and indirectly from activity through the Services, such as through your interaction with the Services.
- From third parties that work with us to provide the Services.
1.2. Vendor List Information. We may obtain information about you after you provide information to a third party and you permit that party (the “Seller”) to share the information, which we subsequently purchase, license, or otherwise lawfully acquire. Such information may include, but not be limited to, your name, street address, zip code, telephone numbers, birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and online interests, and other information which you provided to the Seller (together, “Vendor List Information”). When acquiring Vendor List Information, we require assurances from the Seller that the Seller has a right to transfer the Vendor List Information to us and that we may lawfully use the Vendor List Information in the manner contemplated.
1.3. Technology Information; User Behaviors Collected with Cookies, Web Beacons, and Other Information. We use cookie and web beacon technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as opening or clicking on a particular online advertisement (“Technology Information”). Additionally, we may use other new and evolving sources of Technology Information and information gathering in the future.
(b) Web beacons. A web beacon is programming code used to display an image on a web page and can also transfer an individual users’ identification to a database and associate the individual with previously acquired information about the individual. Web beacons enable us to track certain Web sites you visit or advertisements you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at http://www.webopedia.com/TERM/W/Web_beacon.html.
(c) Where Technology Information is Collected. Technology Information is collected directly from advertisements delivered through the Services or indirectly through third parties that we contract with to display advertisements (“Publishers”). Such advertisements will usually be displayed within one of the following advertising vehicles:
- Websites. We may set a cookie on your computer or device when you view advertisements delivered through the Service or on Publisher websites. After a cookie is set, we may track how you interact with the advertisement and the Services or the Publisher website (for example, registering, purchasing, browsing, etc.).
- Software Programs. The Services may display banner advertisements in your browser or software programs that you may use.
- Email Databases. We and/or our partners may track your interaction with email advertisements sent to you (for example, by setting a cookie on your computer or device) on behalf of Publishers, advertisers or partner websites (for example, when you register, purchase, or browse in response to such email).
1.4. Outside Information. We may lawfully receive information about you from third parties, such as information located in public databases (“Outside Information”).
1.5. No Information Collected from Minors. MINORS UNDER THE AGE OF 18 SHOULD NOT PROVIDE ANY PERSONAL INFORMATION, INCLUDING THEIR EMAIL ADDRESS, TO US. If we are notified that we have personal information about a minor under the age of 18, that information will be promptly deleted from our database.
1.6. Individual Information. As used herein, “Individual Information” means User Information, Vendor List Information, Technology Information, Outside Information, and any other information we lawfully obtain about you. Additional categories of Individual Information will not be collected or used for materially different purposes without first providing you with notice.
2. Use of Information and User Data
How we use and share the information we collect.
2.1. Discretion to Use Information. Information voluntarily provided to us or lawfully obtained by us is our property and may be used by us for any lawful purpose, including the sale, lease or transfer of the information to Publishers, advertisers and data aggregators, for marketing purposes. If you wish to end an email subscription with us or one of our Publishers, you may follow the instructions at the end of each email message to unsubscribe or follow the instructions detailed at Section 6 below.
2.2. General Uses of Information. Information collected by us is used to:
- Fulfill the purpose for which the information was provided by you.
- Perform activities described to you when collecting your information or as set forth in the California Consumer Privacy Act (“CCPA”).
- Provide you with information, products, or services that have been requested.
- Perform internal and external marketing, including delivery of targeted advertisements and information.
- Carry out obligations and enforce contractual rights.
- Improve the Services, such as through testing, research, analysis, and development.
- Respond to requests from law enforcement and government organizations as required by law, court order, or government regulation.
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets whether on an ongoing basis or as part of a discrete transaction in which collected information is among the assets transferred.
Additional categories of information will not be used for materially different purposes without first providing you with notice.
2.3. Targeted Advertising and Information. We may use Individual Information to target advertising and other information, such as business, weather, entertainment, sports and general news alerts and similar information, more effectively. When an individual is online, we may use Technology Information to associate an individual with their Individual Information and attempt to show information and advertising for products and services to which you may respond. We may use data collected from a response to one type of advertising or information for targeting advertisements or other information through a different venue. For example, we may notice that you responded to a baseball banner advertisement and use that response to deliver a baseball-related advertisement and other information to you.
2.4 Legal Process. We may disclose Individual Information to respond to subpoenas, court orders, and other legal process as required by law.
2.5. Summary Data. We may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
We may sell or disclose Individual Information for a business purpose. For example, we may provide your information to service providers who perform services on our behalf or to third party advertisers. In the past twelve (12) months, the following categories of information have been sold or disclosed for a business purpose:
3. How we Store and Protect the Information we Receive
3.1. Storage of Individual Information. We store Individual Information on servers or other equipment that have security measures designed to protect against the loss, misuse, and alteration of the information under our control. We also maintain physical and procedural safeguards designed to protect Individual Information. Notwithstanding such measures, we cannot guarantee that its security measures will prevent Individual Information from being illegally accessed, stolen, or altered.
4. Privacy Practices of Third Parties
4.2. Links. The Publishers’ websites and email messages transmitted by us on our own behalf or on behalf of Publishers may contain hypertext links to the websites of third parties. We are not responsible for the privacy practices or the content of such other websites.
4.3. Affiliated Companies that are not Publishers. We may disclose or transfer Individual Information to entities wholly owned or controlled by us, in our discretion.
5. Your Rights in Information and User Data
5.1. Privacy Rights. You have several rights regarding information collected by us. These include:
- The right to know what categories and specific pieces of information are collected, disclosed for a business purpose, or sold by requesting this information from us.
- The right to request deletion of information collected or maintained by us.
- The right to opt-out of the sale of collected information.
- The right not to receive discriminatory treatment by us for choosing to exercise your privacy rights.
- The right to designate an authorized agent for making requests under the CCPA on your behalf.
6. How You May Exercise Your Rights
6.1. Websites. To prevent the display of Publisher or our advertising on a website, do not visit the website. To only prevent us from tracking your behavior on a website, turn off cookies from that website and do not click on or interact with any advertisements. Please note that we do not have a mechanism or process to respond to any “do not track” signals which a web browser may send or receive, other than as described in this section.
6.2. Email Databases. To unsubscribe from our or Publisher email lists, click the link included in the footer of any message delivered by us or a Publisher and follow the instructions provided. You may also unsubscribe from our network by emailing us at firstname.lastname@example.org .
6.4. Cookies. Check instructions about your web browser to learn how to prevent placement of, or how to remove, cookies placed on your computer or device by us. You can opt-out of receiving cookies from a variety of ad providers and ad servers by visiting the following sites and following the instructions provided: http://www.youronlinechoices.com/ and http://www.aboutads.info/choices.
6.5. Collected Information. To submit a request to know or delete your collected information, please email us at email@example.com. As part of the process of verifying your identity, we will request that you provide us with information accessible to you through the Services. Due to the nature of the information collected, we cannot verify your identity to the degree of certainty required to fulfill requests to know the specific pieces of personal information requested because information collected from you is associated with only two semi-static identifiers. All other information collected from you does not provide a reliable method for verifying your identity. You may opt-out of the sale of personal information by (i) visiting our homepage at https://reachmobi.com/ and submitting requested information through the “Do Not Sell My Info” link, (ii) emailing us at firstname.lastname@example.org or, (iii) indicating that you do not wish to have your information sold prior to submitting it through the Services.
6.6. Designating an Agent. To designate an authorized agent to exercise rights on your behalf, please email us at email@example.com. We may request information from you in order to verify your identity when designating an authorized agent. We may also ask for your authorized agent to provide a written permission from you giving them authorization and verify their own identity by submitting information requested by us.
7. More Information
1010 N. Hancock Street
Philadelphia, PA 19123