Attn: Jonathan A. Flatow, Data Protection Officer
53 Riverside Avenue
Westport, CT 06880
iGain LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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.
The Federal Trade Commission has jurisdiction over iGain LLC’s compliance with the Privacy Shield.
TABLE OF CONTENTS:
- Personal Information We Collect
- Other User Information We Collect
- Information We Receive from Third Parties
- Friend Referrals
- Community Features and User Content
- Third-Party Links
- Advertising Networks and Analytics Companies
- Cookies and Similar Technologies
- Social Features
- Business Transitions
- Digital Fingerprinting
- Updating Your Information; Choice/Opt-out
- Notification of Changes
- Children’s Privacy
- Automated Processing
- Location of Processing and Applicable Law
Personal Information We Collect
When you visit or use any of the iGain Sites and Features or our Services, you may be required to share information that identifies you personally. “Personal Information” refers to any information that can reasonably be used to identify, contact or locate you. Examples of Personal Information may include, without limitation, your name, your location, your credit card number, your email address, your mailing address, and your phone number. We also collect profile data (like occupation, shopping habits, hobbies, interests, product ownership and other areas of interest) as certain elements of our Services may be directed to those participants who meet a particular profile.
Generally, we collect Personal Information when you provide it to us by visiting the iGain Sites and Features or using our Services. This may include registering for any account with us, filling out surveys, joining a mailing list, corresponding with us, entering one of our sweepstakes or contests, choosing to submit testimonials, stories, photos or the like, or otherwise volunteering or providing information about yourself.
If you don’t provide us with your Personal Information, we will generally be unable to provide you with our Services and you will be unable to use the iGain Sites and Features.
You have the right to access your personal data to correct or delete it at any time. All personal data can be found under the “account” section of the applicable website you are a member of, or you can make a request directly via firstname.lastname@example.org, at which time you may request a copy or deletion of your personal data.
Other User Information We Collect
We may collect certain other information each time you visit iGain Sites and Features or use our Services so we can improve the overall quality of your online experience. This kind of information is not ordinarily considered personally identifying information. For example, we collect or may collect your IP address, device ID, referrer data, and browser and platform type. You do not have to register on any of the iGain Sites and Features or provide any Personal Information to us before we can collect this information. We may assign an ID number to your registration and link additional data to that ID number, such as the date and time you visited, the information you provide, and the links you choose to click. Like most standard website servers, we use log files to collect and store this user information. We may analyze and use this information for a variety of purposes, including operating and improving the iGain Sites and Features or our Services, collecting further information about and learning from user behavior and trends, and gathering demographic information. Furthermore, we may combine or link information we collect from or about you offline with information we collect from or about you online through the iGain Sites and Features or your use of our Services.
We may also use GPS or similar geo-location technology to determine the city and/or geo-coordinates of where you are located, including when you are using a mobile device. As noted in the section on “Sharing” below, we may use and share your location information with our advertisers, merchant and survey partners, or others in order to provide you with advertising, content, surveys, offers, promotions, and rewards, or for other marketing, administrative and general business purposes, based on your location.
In addition, our mobile applications may collect, among other things, certain information automatically, including, but not limited to the type of mobile device you use, your mobile device’s unique device identifier (UDID), the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the mobile application.
Information We Receive from Third Parties
We may also receive and supplement the information we directly collect from or about you with information from third parties. If you are on a third-party website or service and you opt-in to receive information from us, the third party may forward to us your e-mail address and other information about you so that we may contact you as requested. In addition, we may receive information from advertisers, merchant or survey partners, and others to ensure that you properly receive any earned rewards or for other marketing, administrative or general business purposes. We may also supplement and combine the information we collect about you with outside records from third parties in order to enhance our ability to provide you with advertising, content, surveys, offers, promotions and rewards, and for other business purposes.
We may provide you with an opportunity to invite your friends, family and acquaintances (“Friends”) to use various iGain Sites and Features. If you elect to use our referral service for informing a Friend about any of the iGain Sites and Features, you will provide us with your Friend’s name and email address. Using our referral service permits us to automatically send the Friend one or more emails or other communications, on your behalf, inviting them to visit or register for the iGain Sites and Features (which invite may include additional subsequent reminders and communications). You warrant and represent that you have your Friend’s consent to provide us with his or her information for this purpose, and that you will not give us referral information for any person not permitted to use the iGain Sites and Features, including, without limitation a child under the age of 13, a person whose account has previously been suspended or deactivated, or a person residing or located in a territory where use of the iGain Sites and Features is not authorized.
Community Features and User Content
The iGain Sites and Features may provide you the opportunity to participate in and post text (including questions, comments, and suggestions), images, audio, videos, or other content (collectively, “User Content”) publicly through our blogs, chat rooms, forums, interactive features, third-party social networking services or other communication functionality (“Community Features”). Please note that certain information, such as your username and profile picture, may be publicly displayed on the iGain Sites and Features along with your User Content. Your User Content may also contain metadata, which may contain information about or relating to you, that we may also collect, share and use.
Advertising Networks and Analytics Companies
We may share your Personal Information and other information with our advertisers, merchant and survey partners, and others for the purpose of making it easier for you to sign up for their surveys, promotions and offers, validating your communications or transactions with them, authenticating and/or validating your identification, crediting you with any earned rewards, and other business purposes. Additionally, we may share information with our service providers and other third parties to assist us in delivering content, advertising, surveys, offers, promotions and rewards to you, both on the iGain Sites and Features and elsewhere online, and for other marketing, administrative and general business purposes.
Cookies and Similar Technologies
In addition to the ad networks, we may set (or allow third parties to set) and access cookies and other similar technologies, such as web beacons and embedded scripts, on your computer. A cookie is a small data file that a website may send to your browser and which may then be stored on your system. We use both session cookies and persistent cookies. For the session cookie, once you close the browser, the cookie terminates. A persistent cookie is a small text file stored on your hard drive for an extended period of time. Persistent cookies can be removed or disabled by following the web browser help-file directions for your particular browser. We also use Flash cookies, which are data files placed on a computer or mobile device via the Adobe Flash plug-in (or other compatible Flash plugin) that may be built-in to or downloaded by you. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Web beacons and embedded script are invisible images or other programming code, which may be used on the iGain Sites and Features for a variety of analytical purposes and to help us provide a better and more customized user experience, including, without limitation, providing personalized features and preferences to you within the iGain Sites and Features; in doing so, we may link the information we collect from cookies and other similar technologies with your Personal Information and may track your browsing activity on our merchant partners’ websites in order to provide you with advertising, content, surveys, offers, promotions and rewards, and for other marketing, administrative and general business purposes.
Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. To opt-out of certain cookies and for more information, please visit http://www.aboutads.info/choices and/or http://www.networkadvertising.org/managing/opt_out.asp. Not accepting or opting out of our cookies may make certain features of the iGain Sites and Features and our Services unavailable to you.
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. At present, we do not believe that there is a consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a user’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
Certain functionality on the iGain Sites and Features may permit interactions that you initiate between the iGain Sites and Features and a third-party website or service, such as Facebook and Twitter (“Social Features”). Examples of Social Features include enabling you to “like” or “share” content from the iGain Sites and Features with other websites or services; to log-in to the iGain Sites and Features using your username and password for a third-party website or service; to transmit content to the iGain Sites and Features from your account on a third-party website or service; and to otherwise connect the iGain Sites and Features to a third-party website or service.
If you choose to use Social Features, information you post or provide access to will be shared with that third-party website or service and others and may be publicly displayed on the iGain Sites and Features or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references any of the iGain Sites and Features (e.g., by using a hashtag associated with any of the iGain Sites and Features in a tweet or status update), your post may be published on the iGain Sites and Features in accordance with the terms of the third-party website or service. Also, both we and the third party may have access to certain information about you and your use of the iGain Sites and Features and the third-party website or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your connections’ web pages, profile pages, or similar pages on a social networking or other third-party website or service.
We may also share your Personal Information with our affiliates for administrative, marketing and other business purposes, and with third-party service providers in connection with the service providers’ performance of services to, or on behalf of, the iGain Sites and Features or our Services. Such services include, for example, customer support, collecting and analyzing information about usage of the iGain Sites and Features or our Services, delivering advertising, content, surveys, offers, promotions and rewards to you on the iGain Sites and Features or elsewhere online, processing payments, and performing other administrative, marketing and other business services.
In addition, if you use our mobile applications, we may share your current location with our partners so that we or our partners may provide you with advertising, content, surveys, offers, promotions, and rewards, and for other business purposes, based on your location. Please see the section on “Updating Your Information; Choice/Opt-Out” below for information about how you can opt out of such sharing.
We may share aggregate or individualized information that may include your use of the iGain Sites and Features or our Services and our merchant partners’ websites, with our advertisers, merchant and survey partners, and others for the purpose of providing you with advertising, content, surveys, offers, promotions, and rewards, and for other marketing, administrative and general business purposes, and we may also receive from ad networks information about third-party websites that you have visited.
The information about you that we share with or receive from third parties may generally be used for marketing, administrative and other business purposes.
Under certain circumstances iGain may remain liable for the acts of Third Parties who perform services on our behalf for their handling of Personal Data that we transfer to them
In the event the Company (or any of its affiliates) goes through a business transition, such as a merger, consolidation, restructuring, acquisition by another company, sale or assignment of rights or assets or a portion thereof, or other company change, we may transfer users’ information, including Personal Information, and other business data in connection with that business transition (e.g., to a subsequent owner, co-owner, or operator of any of the iGain Sites and Features, or any affiliates and trusted agents, service providers, or partners of the foregoing), including during the course of any due diligence process.
Updating Your Information; Choice/Opt-out
You are responsible for maintaining the accuracy of any information you submit to us, such as your contact information.
Certain advertising networks and exchanges may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads. You can learn more about the DAA AdChoices Program here: http://www.youradchoices.com. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (NAI). The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members’ ad networks. To learn more about opting out of targeted advertising or to use the tool, click here: http://www.networkadvertising.org/choices.
If you do not want our mobile applications to collect any information from you, you should uninstall the application using the standard uninstall procedures that may be available as part of your mobile device or via the mobile application marketplace or network where you obtained the mobile application.
Notification of Changes
The iGain Sites and Features and our Services are general audience websites and services and we do not knowingly collect any Personal Information from children younger than the age of 13. If you are under 18, you should use the iGain Sites and Features and our Services only with involvement of a parent or guardian. If you are under 13, you should not submit any Personal Information to us. If we learn that we have inadvertently collected Personal Information from a child younger than 13, we will take commercially reasonable efforts to delete such Personal Information from our databases.
Automated Decision Making / Profiling
We use a combination of automated business rules and statistical algorithms to review your personal information in order to present you with offers, surveys and other features within the iGain sites and our Services for which you are most likely to qualify and most likely to enjoy.
We maintain security measures in place in order to attempt to protect against the loss, misuse and alteration of the Personal Information under our control. Please be advised, however, that the Internet and other various networking communication media are not entirely secure, and your information may therefore be subject to interception or loss which is beyond our reasonable control. While we strive to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you transmit to us, and any transmission is done at your own risk. Accordingly, we assume no responsibility or liability for disclosure of your Personal Information or other information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.
Location of Processing and Applicable Law
Attn: Jonathan A. Flatow, Data Protection Officer
53 Riverside Avenue
Westport, CT 06880