LAST UPDATED: October 5, 2015
HookLogic is committed to protecting the privacy of Internet users and fostering user confidence in the Internet and Internet advertising. We are committed to observing applicable industry guidelines including those established by the Interactive Advertising Bureau and Network Advertising Initiative. We also adhere to the Safe Harbor Principals as established by the European Commission and the United States Department of Commerce. We continually evaluate innovative ways to protect online user privacy while also seeking to deliver relevant advertising and custom online experiences.
The next few sections below describe how we collect User information in connection with the operation of our Programs for our Advertisers as well as this Site.
By using this website or our Programs, you agree to the terms and conditions of this Policy. 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 this Site. Use of this Site or any of our Programs following such changes constitutes your acceptance of the revised Policy then in effect.
1. What Information Do We Collect?
PII. PII 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 an Advertiser, register for a webinar, receive emails about market trends/research we’ve done), we may require that you furnish PII.
Non-PII. Non-PII includes information received from the web browser, operating system, or device, including such things as information about the browser and browser settings, information about the operating system or device, the unique identifier assigned to a device, the web address of a web page visited, MAC address, the computer’s Internet protocol (“IP”) address, the name or type of mobile app, demographic data (for example a User’s country) the time and date a web page or app was visited, the address of the referring web page, search terms a User has entered, what Products a User has put into a Property shopping cart, what products a User has purchased and other information about a web page or app. It could also include the number of times a particular browser or device has been shown a particular ad, or it may include generic categories about users and their interests (for example, “female laptop buyer”). Non-PII also includes information about the precise geographic location of the device, which may be collected when the user of the device permits such collection.
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.
2. How Do We Collect Information?
We collect PII from Advertisers that sign up to use our Programs, such as name, postal address, telephone number, e-mail address, credit card number or other payment account number, only when it is voluntarily provided to us. Our Programs do not collect or use PII from Users. We also collect PII through the “Contact Us” form on this Site.
Cookie. A cookie is a file on your browser that uniquely identifies your browser and computer. Cookies are stored as text files on users’ hard drives, and can be accessed by web servers when user visit a website or views an advertisement. Cookies are used by companies to collect and send information about a user’s website visit – for example, number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. When a User visits a Property, the Publisher of that Property sends us an encrypted unique identifier that allows us to search our database to determine whether that user is in our database. If a match occurs, we associate the cookie data with data about the User on behalf of our Advertisers. The cookies placed by our Programs cannot be used to access any other data on users’ hard drives, or to personally identify them.
Pixels, Beacons, and Tags. Pixels (also referred to as a beacon) and tags are lines of code which are used by a website or third party to assign online activities to a computer or browser. The use of a pixel or tags allows Properties and our Site to record, for example, that a user has visited a particular web page. They also allow us to serve advertising and provide related services such as measurement or fraud prevention. Additional Non-PII from an earlier period or interaction may be included in the pixel.
3. For What Purposes Do We Use the Collected Information?
PII. We may use PII:
- for the purpose for which it was provided (e.g., to provide services and/or to send requested information to Advertisers and users of this Site).
- for billing and customer care purposes.
- to respond to problems and comments.
- to approve and enable user participation in the Site and Advertiser participation in our Programs.
- to permit users of this Site and Advertisers to participate in a webinar.
- to permit Advertisers to use our client login and the services offered therein (e.g., to permit review of billing), as applicable.
- to inform Advertisers or users of this Site of products, programs, services and promotions that we believe may be of interest.
- to send Advertisers and users of this Site 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 this Site, improving our Programs, identifying usage trends and determining the effectiveness of our promotional campaigns.
- as we believe to be 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 permit us to pursue available remedies or limit the damages that we may sustain.
Our technology does not use any PII to serve advertisements to customers and we do not sell any PII under any circumstances.
Non-PII. Because Non-Personal Information does not personally identify you or a User, we may use such information for any purpose. In addition, we reserve the right to share such Non-PII, which does not personally identify you or a User, with affiliates and other third parties, for any purpose.
We use Non-PII to identify computers that we have interacted with before. For instance, by using Non-PII, we may be able to identify a computer that has previously seen an advertisement we launched on a Property. Through the collection and use of Non-PII, we allow Advertisers to show Users the most useful and relevant online advertisements across the Network and to determine which Users are likely to value product or service advertising. We also use Non-PII to limit the number of times a User sees a particular advertisement, show advertisements in a particular sequence, customize advertisements to a particular geographic region, determine when Users click on advertisements, to perform attribution analysis or other analysis regarding advertising impact and to report aggregated statistical data to Advertisers. You can learn more about such advertising practices by visiting www.iab.net/privacymatters.
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 PII. Please note that we treat IP Addresses, server log files and related information as Non-PII, except where we are required to do otherwise under applicable law.
4. What Information Do We Share With Third Parties?
We may share PII with third parties (affiliates, subsidiaries and vendors) who provide services to us or perform services on our behalf. However, third parties are not permitted to use such user information for any purpose other than performing or providing services to us.
We may share PII with 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).
We may disclose PII to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person.
We may disclose Non-PII collected through our Programs, and information derived from it, to our Advertisers, Publishers and vendors. This Non-PII may be used by our Advertisers to deliver tailored ads to users on participating websites and for other purposes as described above. This information does not include any PII that can be used to contact or identify any person individually. Further, we encourage our Advertisers and Publishers, as applicable, to use any Non-PII they receive in compliance with applicable laws and regulations and to publish privacy policies that tell you about how the information they are gathering is being used. We urge you to always read the privacy policies of the websites you visit to understand issues relating to your online privacy.
HookLogic may deliver advertising to websites owned by third-party publishers that are not part of the Network (“Non-affiliated Properties”). Please note that the owners of these Non-Affiliated Properties may use information (not including PII) about you in order to provide advertisements about goods and services that may be of interest to you.
5. Information We Collect Through Your Correspondence on this Website
If you provide us information through our “Contact Us” link on this website, sign up to receive our marketing emails or newsletters, submit information in connection with an employment inquiry, expressly enter information into a text field or otherwise submit information to us, we will keep a record of the information you provide including your email address and any other PII you provide solely for the purpose of responding to your inquiry or to provide you with requested marketing materials or newsletters. Except as set forth in this Policy, this information will never be shared with third parties without your consent. We may also disclose your information to third parties in the event of suspected fraud, legal requirement or in connection with our vendors and contractors, all as described above.
6. How is the Information Stored?
Information Security / Integrity. We use reasonable organizational, technical and administrative measures to protect PII 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.
Retention Period. We will retain your PII for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
7. What are your choices?
Marketing Opt-Out. If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving such marketing-related emails or from such sharing by sending an email containing your request to privacy@HookLogic.com.
We will endeavor to comply with your request as soon as reasonably practicable. 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.
Interest-Based Advertising Opt-Out. Some of the ads you receive when you visit Properties in the Network are customized based on predictions about your interests generated from your visits over time. This type of ad customization is called interest-based advertising. You can find out more about interest-based advertising here.
You may opt out of HookLogic interest-based advertising by clicking on the tool below. When you opt out, we will place an HTTP opt-out cookie onto your browser. Accordingly, for the opt-out to function, your browser preference must be set to accept third-party cookies. This opt-out cookie must be maintained on your browser in order for us to know that you have opted out of interest based advertising. If you delete your cookies, or if you are using a different web browser or device, you will need to opt out again.
If you opt out of interest-based advertising, you will still see advertisements. However, the ads delivered by HookLogic will not be customized based on your interests and web usage patterns.
Accessing, Changing or Suppressing Personal Information. If you would like to 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 privacy@HookLogic.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.
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.
8. U.S. – E.U. and U.S. – Swiss Safe Harbor Frameworks
HookLogic complies with the U.S. – E.U. and U.S. – Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. HookLogic has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program and to view HookLogic’s certification, please visit http://www.export.gov/safeharbor. Unresolved privacy complaints under either of the Safe Harbors will be referred to the American Arbitration Association as an independent dispute resolution mechanism.
9. Miscellaneous Items.
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.
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. 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.
99 Hudson St., 9th Floor
New York, NY 10013
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.