Effective Date of Current Policy: Aug 14, 2022
WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Information You Voluntarily Submit to the Website: It is not necessary to provide any Personal Data to use the Website. You can visit much of the Website without telling Company who you are or submitting any Personal Data. However, in order to take advantage of certain features available through the Website, it may be necessary to provide Personal Information. We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, send a comment or question or enroll in a feature.
Personal Data may include, but is not limited to, the below:
- First name
- Last name
- Your email address
- Mailing address
- Company name
- Phone number
Automatically Collected Information and Information We Collect from Others.
We may receive information about you from other trusted sources, such as information that validates or supplements information automatically collected. We collect information about the device you are using; tools and protocols, such as IP (Internet Protocol) addresses and device’s geolocation; and other similar data for the purpose of optimization only.
When you use the Website, we may log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect usage data, which is information about actions you take when using the Website, such as links clicked.
Please see the sections about how your information is used and third-party providers to see how this data is used and shared.
We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website. Our legal basis for processing this information is your consent and our legitimate interests, namely monitoring and improving the Website and services.
What are cookies?
A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website and through the services. The cookie will collect information relating to your use of our Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Website and services via a link from a third party site, the URL of the linking page.
In addition to cookies, our Website may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only a 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
What are the different types of cookies and how do we use them?
Essential/Necessary – These are cookies which are essential for the running of our Website and services. Without these cookies, parts of our Website and services would not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential cookies include:
- Setting unique identifiers for each unique visitor, so that Website numbers can be analyzed.
- Optimizing user experience.
- Storing user consent for data collection.
Functional – These cookies are used to remember your preferences on our Website and services and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional cookies include:
- Gathering data about visits to our Website and services, including numbers of visitors and visits, length of time spent on the site, pages clicked on or referring URL.
- Eliminating the need for returning users to re-enter their login details.
- Confirming browser language.
Analytical Performance – Analytical performance cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users our Website and services have. We use this information to improve user experience or identify areas of the Website and services which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical cookies include:
- Measuring users’ behavior.
- Analyze which pages are viewed and how long for.
- Analyze which links are followed to better develop our Website and services.
- Determining whether a visitor the Website is new or returning.
Advertising – Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on the web more relevant to you. Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally.
Examples of how we may use advertising cookies include:
- To market to specific users across our Website, and third party websites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
- To facilitate social sharing features.
- To create a unique ID for each visitor to the Website to present relevant advertising.
Third Party Cookies – You may notice on some pages of our Website and services that cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own cookies on your device. We do not control the use of these third party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third party website for more information about these cookies.
How can you manage or opt-out of cookies?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies. Deleting or blocking cookies may reduce functionality of the Website and the services. To learn more about how to reject cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics cookies, please do so by clicking on the links below:
Google Analytics: https://tools.google.com/dlpage/gaoptout
Opting out of Behavioral Advertising Cookies
If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
HOW YOUR INFORMATION MAY BE USED
The Website may use the information collected in the following ways:
- To operate and maintain the Website;
- To oversee sweepstakes, contests or promotions;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- For internal training and quality control;
- To track and measure advertising on the Website; or,
- To protect, investigate, and deter against unauthorized or illegal activity.
Company may use your Personal Data that you submit for only limited purposes. Company uses Personal Data you provide to provide you with the information and services that you request. Also, Company may use your Personal Data in aggregate form to help evaluate and modify existing services and to help develop additional services that are likely to be of interest to visitors of the Website.
Non-Identifiable Data: When you use the Website, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents, or service providers. We may use such information and pool it with other information to track, for example, user behavior. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Website, Company may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. Company may use this non-personal information in aggregate form for product and service development, for market analysis, and to understand how to improve the quality of the Website. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents and business partners. This aggregated information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our customers to current and prospective business partners, and to other third parties for other lawful purposes.
Anonymous Data: From time to time, Company may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.
THIRD-PARTY USE OF PERSONAL INFORMATION
Company may share your Personal Data with certain third parties as set forth below:
Third Party Vendors: We may share your information with third party vendors or service providers who help us provide our products or services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, or (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.
The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:
- Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
- Google Forms – this services is used to collect information from sweepstakes or contest winners that we may run on behalf of Company clients. The information collected is only used to verify the identity of winners and to facilitate prize collection.
- MailChimp– this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.
- SegMetrics. We use SegMetrics on behalf of our clients to provide anonymized data about user behavior on websites owned by our clients.
- Creator IQ. We use Creator IQ to store, track and measure analytics and other information in connection with influencers that we or our clients may work with, such as their email, address, tax status or payment information. Creator IQ may also use information such as identifiers and internet activity including names and handles, bio, profile picture and interests, public posting activity, public conversations, engagement, followers and follower counts, brand affiliations.
- Hype Auditor. We use Hype Auditor to store, track and measure analytics in connection with influencers that we or our clients work with such as a link to influencer’s profile, full name, avatar, language, biography, country/city/state, brand and common interests, notable engaged users, sponsored posts, email and social network profile and images, graphics, photos, profiles, audio and video clips, sounds, musical works, liaisons with audience, texts of the comments, works of authorship, applications, links and other content or materials from their social network profile. We also receive analytics from such influencer’s audience such as gender, age group and ethnicity.
- Pipeline- We use Pipeline as our CRM software provider. We may use the software to track our communications with clients and sales information including your information such as name and email address.
- Google Drive – We use Google Drive to store business records and communications which may include your information such as name or email address.
At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Website’s sole discretion.
Except when required by law, Company will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Company may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
Facebook: Opt-out of Facebook remarketing here
Google: Opt-out of Google remarketing here
Pinterest: Opt-out of Pinterest remarketing here
LinkedIn: Opt-out of LinkedIn remarketing here
Instagram: Opt-out of Instagram remarketing here
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, Company may see if and when you open an email and which links within the email you click. Also, this allows Company to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
Receiving Promotional Materials.
Company may send you information or materials such as emails or newsletters by e-mail or postal mail when you submit your e-mail or postal mail address via the Website or an affiliate’s website. You may “opt-out” of receiving the e-mails by using the unsubscribe feature included in the e-mails you receive. Also, if you do not want to receive this information or materials, you can send an email with your name, mailing address and email address to [email protected] When Company receives your request, Company may take reasonable steps to remove your name from its address lists.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT
We will keep your personal information while you subscribe to your mailing list or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf.
- To show that we treated you fairly.
- To keep records required by law.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Opt-out – If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications. You may also notify us at [email protected] to be removed from our mailing list.
Access – You may request access to the personal information we have about you by submitting a request to [email protected]
Amend – You may contact us at [email protected] to amend or update your personal information.
Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to [email protected]
Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.
LEGAL BASIS FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
We are responsible as a “controller” of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
- Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person.
How to File a GDPR Complaint.
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
WHERE YOUR PERSONAL DATA IS HELD
Personal Data may be held at our offices and those of our affiliates, parent, or related companies, third party agencies, service providers, representatives and agents as described above (see above: “Third Party Use of Personal Information”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below.
Transferring Your Data out of the EEA
If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:
- the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
- we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses and required additional safeguards with the recipient, such as pseudonymization or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority; or
- the data has been anonymized and cannot identify you.
SENSITIVE PERSONAL INFORMATION
NOTICE TO CHILDREN UNDER THE AGE OF 13 AND THEIR PARENTS OR LEGAL GUARDIANS.
THE WEBSITE IS ONLY INTENDED FOR ADULTS AND IS NOT DIRECTED TOWARD CHILDREN UNDER THE AGE OF 13. COMPANY DOES NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF 13. IF YOU ARE UNDER THE AGE OF 13 AND WOULD LIKE TO CONTACT COMPANY PLEASE DO SO ONLY THROUGH YOUR PARENT OR LEGAL GUARDIAN. IF YOU ARE UNDER THE AGE OF 13 PLEASE DO NOT SEND COMPANY ANY PERSONAL INFORMATION INCLUDING WITHOUT LIMITATION YOUR EMAIL ADDRESS, NAME AND/OR CONTACT INFORMATION. IF YOU ARE THE PARENT OR GUARDIAN OF A CHILD UNDER THE AGE OF 13 WHO YOU BELIEVE MAY HAVE PROVIDED PERSONAL INFORMATION TO COMPANY, PLEASE CONTACT COMPANY AND COMPANY WILL PROMPTLY DELETE SUCH INFORMATION FROM ITS FILES.
LINKS TO OTHER WEBSITES
The Website may contain links to other websites not operated or controlled by Company (the “Third-Party Sites”). The policies and procedures described here do not apply to the Third-Party Sites. The links from the Website do not imply that Company endorses or has reviewed the Third-Party Sites. Such links do not constitute an endorsement of those third parties, or the content displayed on their sites. Company provides these links to you only as a convenience, and any information you provide to those third parties will be used as described by the third parties in their own privacy policies. Company does not have any liability for your use of such websites. You acknowledge and agree that your use of such websites is at your sole option and risk.
OTHER TERMS AND CONDITIONS
Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Company. Please refer to those agreements as needed.
6516 North Gessner Drive
Houston, Texas 77040
Email: [email protected]
Last updated: August 15, 2022