We and our third-party service providers (including any third-party content, advertising, and analytics providers) automatically collect certain information from your device or web browser when you interact with the Services to help us understand how our users use the Services and to target advertising to you (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Services we and our third-party service providers automatically collect your IP address, mobile device identifier or other unique identifier, browser and computer type, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on the Services.
We and our third-party service providers use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.
We use tracking technologies, such as cookies, local storage, and pixel tags.
Cookies and Local Storage
Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Services, a cookie or local storage will be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer’s browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each Web site can send its own cookie to your browser. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.
Our Services use the following types of cookies for the purposes set out below
We also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.
We use pixel tags, either provided by us or by our third-party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Pixel tags also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.
In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes.
For more information about the use of cookies and similar technology on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org and http://www.youronlinechoices.com/uk.
You can visit the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual (which we will refer to in this Privacy Policy collectively as “Personal Data”). If, however, you wish to register to become a member of the Services, you are required to provide certain Personal Data (for example, your name and e-mail address), and you must also provide a user name and password. We use your Personal Data to fulfill your requests for products and services, to improve our Services, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Privacy Policy. In addition, you are required to provide certain Personal Data when you submit a job application and supporting materials. Where you submit a job application on behalf of another person, you confirm that you have made that person aware of how we collect, use and share their Personal Data, the reason you have provided it, how they can contact us, the terms of this Privacy Policy and related policies and that they have consented to such collection, use and sharing. You can also choose to submit or we may collect additional information about yourself, such as demographic information (for example your gender, birth date, or zip code) and information about your preferences and interests. Failure to provide any required Personal Data will prevent us from being able to provide the Services you request (e.g., member registration or submission of job application) or otherwise inhibit our ability to provide the Services.
We refer collectively to all information we collect that is not Personal Data, including Usage Data, demographic data and de-identified Personal Data, as “Non-Personal Data”. If we combine Non-Personal Data with Personal Data, we will treat the combined information as Personal Data under this Privacy Policy.
You also can choose to submit your alias, bio, email, photos or any other information that you would like to share with other users of the Services (which we will refer to in this Privacy Policy collectively as “User Submissions”).
Personal Data, Non-Personal Data, and User Submissions are referred to in this Privacy Policy collectively as “User Information.”
Information We Receive From Other Sources
We supplement the information we collect with outside records in order to learn more about our users, to better tailor the content and offers we show you, and for other purposes. We receive this information about you from public sources or third parties, including without limitation consumer data resellers and advertisers. We combine the information we receive from those other sources with information we collect through the Services. In those cases, we will apply this Privacy Policy to the combined information.
We use the information we collect, including Personal Data and Usage Data:
to enable you to use our Services, to create an account or profile, to process information you provide via our Services (including verifying that your email address is active and valid) and to process your transactions;
to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses;
to provide you with information, products, or services that you have requested;
to receive and process job applications for jobs with us;
with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third-party partners;
to tailor content, recommendations, and advertisements we and third parties display to you, both on the Services and elsewhere online;
for internal business purposes, such as to improve our Services;
to administer and process contests, sweepstakes, and promotions;
to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of our other policies;
to comply with regulatory and legal obligations; and
for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.
(a) Generally. We share Non-Personal Data, including Usage Data, de-identified Personal Data and aggregated user statistics, with third parties in our discretion. We share User Information, including Personal Data, as otherwise described in this Policy, and under the following circumstances:
(b) Service Providers. From time to time, we enter into relationships with third parties who provide services to us (for example, analytics companies, advertisers and ad agencies, data management and storage services or credit card processing services, sweepstakes or contest prize fulfillment). In those circumstances, we disclose User Information so that such service providers perform those services. These service providers are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data. In particular, our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which enable collection and sharing of your information (including Personal Data) with Google for further use. For specific information on Google usage and how to control it, please see How Google uses data when you use our partners’ sites or apps and Google’s Privacy Policy.
(c) Third-Party Marketing. You will have a choice (opt-in or opt-out) before we share your information with third parties for marketing purposes. Provided that you have chosen to receive marketing messages from third parties, we share your information (including Personal Data) with third parties for those third parties’ own direct marketing purposes. Please note, messages delivered from a third-party will subject you to the third-party’s privacy policy. We also match your email address with third parties with whom you have also consented to share your email address and use such match to deliver custom offers or emails to you on the Services and off the Services provided you have consented to receiving such offers or emails.
(d) Change of Control. In the event we go through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of our assets, including, without limitation, during the course of any due diligence process), your Personal Data will likely be among the assets transferred. By providing your Personal Data, you agree that we can transfer such information in those circumstances without your further consent. Should such a business transition occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Policy with respect to your Personal Data. If your Personal Data would be used contrary to this Privacy Policy, we will request that you receive prior notice.
(e) Other Disclosure Scenarios. We reserve the right, and you hereby expressly authorize us, to share User Information: (i) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (ii) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (iii) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (iv) to protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the general public; and (v) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy).
Public Information
The Services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen such as the European Union. You understand that the U.S. government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We use appropriate and suitable safeguards for transferring your Personal Data to the U.S. (e.g., standard contractual clauses issued by the European Commission, which can be accessed here).
Important Information for California Residents-Your California Privacy Rights
As stated elsewhere in this Privacy Policy, WireWink does not share Personal Data with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us at contact@wirewink.com. You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone, email, or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.
Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how WireWink responds to “Do Not Track” browser settings.
There currently is no consensus among industry participants as to what “Do Not Track” means in this context. Therefore, like many websites and online services, the Services do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
(a) Generally. We use other companies under agreements with us to serve third-party advertisements when you visit and use the Services. These companies collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one.
(b) Targeted Advertising. In order to serve offers and advertisements that may be of interest to our users, we display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Data to our advertisers when you interact with an advertisement.
(c) Your Ad Choices. Some of the third-party services providers and/or Advertisers may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You can visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You can opt-out of our use of your Web site viewing behavior data to serve you interest-based advertising on third-party sites and email newsletters here http://www.aboutads.info/choices.
If you are accessing the Services through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device’s application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information, visit http://www.aboutads.info/appchoices.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.
(d) Mobile. We may from time to time offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorize us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we also collect and store certain information about the users who elect to use such location-based services, such as a device id. This information will be used to provide you the location-based services. We use third-party providers to help provide location-based services through mobile systems (unless you opt out of such location-based services with such providers) and we provide the information to such providers to enable them to provide their location-based services, provided that such providers use the information in accordance with our Privacy Policy.
You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us, please let us know by accessing and updating your profile. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law.
Please note that we need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such promotion). We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, 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 Services or otherwise to us.
If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.
Email Promotions. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
The Services are intended for a general audience and are not intended for and should not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target the Services to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below. We will delete such information from our files as soon as reasonably practicable.=
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, 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 Services or otherwise to us.
If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.
If you have any questions about this Privacy Policy, please feel free to contact us by email at contact@wirewink.com.
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