Parrable

Privacy Policy

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General Privacy PolicyEffective: September 10, 2020 Parrable maintains two privacy policies, a general privacy policy, and a GDPR specific privacy policy. Parrable, Inc., its subsidiaries, and affiliates (known as “Parrable,” ”We,” “Our,” or “Us”) collects certain identifying information as part of our business and identity solution (“Services”). This information allows us to provide persistent and stable information on website audiences. Without access to such information, our Services would not be possible. We take seriously our responsibility to facilitate privacy rights fairly under applicable law. This Privacy Policy provides transparency about our privacy practices, including how we collect, process, and disclose personal information, and how you can control and manage your privacy choices. The actual administration of your privacy rights may vary based on your unique circumstances and the laws applicable to you.Scope and ApplicabilityThis Privacy Policy applies to our Services, wherever operated, as well as information collected through our sales and marketing website at www.parrable.com/. Our relationship with you determines how this Privacy Policy applies to your information. For example, as a user of our website, we may collect certain personal information as part of that interaction. In other circumstances, we may process your information as a “Service Provider” to our Partners. In such cases, the privacy policy of our Partners may apply in addition to certain portions of our privacy policy. If you have any question as to who is responsible for your information, please contact us at privacy@parrable.com.Information We Collect and ReceiveParrable collects some personal information directly and other information (Parrable IDs) are collected in our capacity as a “Service Provider” from our Publisher Partners under the California Consumer Privacy Act (CCPA) of 2018 and Nevada’s 2019 privacy amendment (Nevada Amendment). Specifically, we collect or receive the following categories of personal information:  Parrable.com Users1Business Contacts2Parrable ID Users3Log DataInformation collected by our servers when you access our website, including IP addresses, referral URLs, user agent, date and time of usage, language preferences, and cookie dataX XContact InformationYour name, phone number, email address, and mailing address, etc.XX Parrable IDA unique ID created by Parrable and linked with your device and browser.X XPartner Provided IdentifiersInformation sent to Parrable by partners may include mobile advertising identifiers (e.g., IDFA or AAID), and Partner Identifiers.  X<ol> <li>Parrable.com Users: Users who access our website at www.parrable.com/ and/or engage with us through our webforms or other online contact methods </li> <li>Business Contacts: Individuals whose information we collect through various means for sales and marketing or other routine business purposes</li> <li>Parrable ID Users: Users who access the websites of our Partners and receive a Parrable ID</li> </ol>Our Uses of Personal InformationOur use of personal information depends on the type of information as discussed below and is limited to the purposes disclosed in this Privacy Policy (or through other notice) and any other purpose that you may intend or direct through your interactions with us. Parrable IDs Parrable IDs are collected by us through our Publisher Partners as a “Service Provider” to our Publisher Partners. Parrable IDs are used exclusively to provide and improve our Services to our Partners. Business Data Other types of personal information, including Business Data, are used for providing our Services and operating our business, which includes traditional business purposes, such as: <ul> <li> <ul> <li>Administering accounts</li> <li>Communicating through email and other means</li> <li>Promoting our services through sales and marketing</li> <li>Detecting and preventing abuse and security issues</li> <li>Complying with legal and regulatory obligations</li> </ul> </li> </ul> If we deidentify your personal information to the extent that it is anonymized either through aggregation or other means, such information is no longer considered “personal information.” We may use such information for any legal purpose without providing you with additional notice.How We Share Information Parrable IDs We share and disclose Parrable IDs with our Partners as part of our contracted Services for our Partners. Our transfer of this information as a Service Provider to our Partners is governed by the terms and instructions of our contracts with our Partners and does not constitute a “sale” of personal information by Parrable under the CCPA and the Nevada Amendment. Our Partners determine the means and purposes of the sharing or disclosure of personal information. Parrable, as a Service Provider, may share or disclose personal information only under the conditions that are set out or required under the CCPA and the Nevada Amendment to fulfill our contractual or legal obligations. The categories of parties (including service providers and third parties by Partner contract) with whom we may share Parrable IDs with include:PartnersParrable may share ParrableIDs among partners as directed by those partners.IT Service ProvidersWe may share Parrable IDs with our IT service providers as needed to operate our Services, including with our information technology and web hosting providers.Corporate ActivitiesWe may share Parrable IDs with potential investors or lenders and as part of a transaction involving a merger, acquisition, divestiture, public offering, or similar transaction involving our business.Government and LegalWe may share Parrable IDs with third parties as may be required by applicable law, regulation, or legal process.Business Data We share and disclose Business Data with service providers as needed to provide our Services and operate our business. However, we do not “sell” this type of personal information as defined by the CCPA and the Nevada Amendment. The categories of service providers with whom we may share Business Data with include:IT Service ProvidersWe may share Business Data with our IT service providers as needed to operate our Services, including with our information technology and web hosting providers.Business ServicesWe may share Business Data with our business services providers, including security vendors, contract developers, auditors, analytics services, and legal and accounting advisors.Corporate ActivitiesWe may share Business Data with potential investors or lenders and as part of a transaction involving a merger, acquisition, divestiture, public offering, or similar transaction involving our business.Government and LegalWe may share Business Data with third parties as may be required by applicable law, regulation, or legal process.California Consumer Privacy Act (CCPA)The following provisions apply only to California residents as defined by the CCPA and supplement our broader Privacy Policy: Business and Service Provider Roles and Relationships Under the CCPA, Parrable may be a Business or a Service Provider with respect to your personal information, depending on the circumstances. If we are responsible for your personal information as a Business or have otherwise been delegated the responsibility as a Service Provider, we will respond directly to your privacy requests. If we are processing your information as a Service Provider you may choose to exercise your data protection rights directly with the Business, such as our Publisher Partners, e.g. the website that collected your data. Otherwise, if you wish to make your request to us, we will forward your request to the responsible party. Sales of Personal Information In our capacity as a Business under the CCPA, Parrable does not “sell” personal information. However, our transfer of Parrable IDs as a Service Provider to our Partners would not be a “sale” of personal information per our contractual obligations to our Partners. In the preceding twelve (12) months, we may have transferred Parrable IDs to our Partners. Privacy Rights of California Residents If you are a California resident, subject to certain limitations, you have the following rights concerning your personal information: <ul> <li> <ul> <li> <ul> <li>Right to Know. You have the right to access the specific pieces of personal information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format if you have a password-protected account.</li> <li>Right to Deletion. You have the right to request that we delete any of the personal information we have collected or maintain about you.</li> <li>Right to Opt-out of Sales of Personal Information. You have a right to opt-out of the sale of your personal information and to opt-in again at your election.</li> </ul> </li> </ul> </li> </ul> Exercising Your Rights Under the CCPA You may exercise your rights by submitting a request to our Data Protection Officer at privacy@parrable.com. The CCPA allows for 2 disclosure requests per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request. If you would like to opt-out of the sale or sharing of your personal information by Parrable, you can opt-out by using the opt-out tool available here: www.parrable.com/opt-out/. We respond to and process requests promptly and within the timeframes required by the CCPA. Please note that all requests are subject to proper prior verification before processing as required by the CCPA.Data Retention and DisposalWe retain and dispose of personal information according to our data retention and disposal policies, which are designed to meet the requirements of applicable law. Generally, this means: <ul> <li> <ul> <li>Parrable.com User data is retained only for as long as is necessary, including a reasonable time after its collection to ensure the integrity of log files, prevent fraud and spoofing, and protect the security of our Services.</li> <li>Business Contact information is retained for as long as may be necessary for the purposes for which it was obtained, including any possible follow ups.</li> <li>Parrable IDs are retained in accordance with our obligations as a Service Provider or for as long as the ID has not been opted out.</li> </ul> </li> </ul> As part of our backup and recovery policies, deleted data may remain in our possession for an additional period in the form of secure backups.Exercising Control Over Your PrivacyWe provide several ways to exercise control over your privacy. You may opt out of Parrable IDs at any time directly on our Publisher Partners’ websites or globally by using the opt-out tool available at: www.parrable.com/opt-out/. You may also exercise your applicable rights by contacting us at privacy@parrable.com. All privacy requests are subject to proper prior verification and fulfilled to the extent that the law may require.Cookie Notice and “Do Not Track” RequestsThe following applies only to our website located at www.parrable.com/: We use cookies on our website for various purposes, including to measure user interactions and personalize your user experience. When accessing our site, you may be presented with the opportunity to opt-in or opt-out of certain types of cookies, not including essential cookies, which are necessary for the operation of the site. Other types of cookies include performance cookies. Performance cookies are used for analytical purposes. For example, we use Google Analytics to collect and measure visits and traffic to our website. You can learn how Google uses such data here: www.google.com/policies/privacy/partners/. In such cases, the privacy policies of these third parties, including Google, will also govern the use of your personal information. Under the California Online Privacy Protection Act (CalOPPA), we want to inform you about our “Do Not Track” (“DNT”) request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. Parrable does not share data collected through the website and thus does not change data collection behavior based on the presence of a DNT request.You can learn more about DNT here: www.eff.org/issues/do-not-track.Children’s DataUnder the Children’s Online Privacy Protection Act (“COPPA”) and other laws, our website and associated services are not marketed to children under sixteen (16) years of age. We do not intentionally collect information from children. We encourage parents and guardians to take appropriate steps to ensure the safety and privacy of their children online.Direct Marketing DataUnder California’s “Shine the Light” law, we do not disclose the defined types of personal information to third parties for their direct marketing purposes.UnsubscribeIf you wish to unsubscribe from Parrable’s sales and marketing emails, please follow this link: unsubscribe@parrable.com.Information SecurityWe work hard to protect personal information through commercially reasonable and appropriate security measures. Our efforts include utilizing encryption and physical, technical, and administrative controls to prevent the unauthorized access and disclosure of personal information. However, we encourage all users to exercise due care when interacting with our website and services, just as one would with any other website. Parrable will never ask you for a password. If needed to verify your identity in responding to privacy requests, we may ask you for other personal information to confirm your identity.Breach NotificationIf any of the personal information we retain about you is the subject of a breach of personal information under applicable law, we will take appropriate actions, including providing you with notice of such breach, as such law or laws may require.Changes to This Privacy PolicyWe may update this Privacy Policy from time-to-time. If we make any revisions to this Privacy Policy, we will revise the “Last Updated” date below. If such changes represent material differences in the purposes for which your personal information was originally obtained, we will provide you with additional notice and request that you consent to such changes. Notice may be provided by adding a statement to the main website page or by sending you an email or other notification, as may be appropriate to the circumstances. How to Contact Us For inquiries about this Privacy Policy or to make a request or file a complaint, please contact us at the information below: Parrable Data Protection Officer 330 E. Liberty St. Ann Arbor, Michigan 48104 United States Email: privacy@parrable.com This Privacy Notice was Last Updated: September 10, 2020.