(Postcards only, please)
c/o Privacy Department
556 S. Fair Oaks Ave. #188
Pasadena, CA 91105
Revised and Effective Date: July 31, 2020
We do not collect sensitive data, as defined by GDPR (See GDPR Article 4(1) ), that refers to information that reveals the race or ethnic, religion or philosophical beliefs, sexual orientation, political affiliation, trade union membership, health/medical status or information, genetic/biometric data.
When submitting any data directly to us on our website, Interpolls is the data controller and our Data Protection Officer can be contacted by email: firstname.lastname@example.org.
When providing our products and services to Advertisers, Agencies, Publishers, and its Agents (collectively “Clients”), Interpolls does not act as a data controller, but generally as a data processor for these clients. Interpolls processes such data based on the Client’s instructions, which means the Clients are responsible for the processing of your personal data.
Interpolls provides Advertisers, Agencies, Publishers and its Agents the tools and services to create and deliver advertisements (also referred to as ad-serving) that you may encounter on certain web sites, monitor the performance of those advertisements, manage ad creatives for campaigns, and deliver advertisements that most likely will be relevant and interest you. When Users interact with ads generated using the Interpolls Services, we may collect information on behalf of Interpolls’ Clients. Interpolls provides promotion tools and services for clients to create, manage and deliver sweepstakes or contests to users for a chance to win or earn prizes. Lastly, Interpolls provides interactive content features, such as polls, trivia, or other engagement features that can be displayed on the Client web page, its ad units, or both. Interpolls does not sell, distribute or share any of the data from its products or services to any third party.
PERSONALLY IDENTIFIABLE INFORMATION
Personally Identifiable Information ("PII") is individually identifiable information about a particular individual that permits the physical or online contacting of such individual. Examples of PII include (without limitation):
Please note: PII is only collected by us in connection with our Website, Products, Services, and Platform where users voluntarily submit such PII.
NON-PERSONALLY IDENTIFIABLE INFORMATION
We collect and use Non-Personally Identifiable Information ("Non-PII"), which is any information other than PII and does not identify the specific individual. Non-PII includes without limitation: IP address, the approximate geographic location of the User based on their IP address the type of browser and operating system used by the User, the number of ad units delivered to each website(s), the date and time the ad unit was delivered, any interactions a User may initiate within the ad unit, the websites and web pages that users visit or visited, the type of Product delivered by us that users view on websites they visit, user interactions with features, content preferences user interact within ad units, and other inferences about the user's interests made based upon the foregoing (“Ad interaction Data”). This Non-PII is aggregated by our Platform and does not personally identify any single user.
COLLECTING PERSONAL DATA BASED ON CONSENTS
COLLECTING PERSONAL DATA BASED ON LEGITIMATE INTEREST
For our Website, PII is only collected when a user submits a specific request for information or requests to be contacted by us through our Website submission form, or sends certain e-mail communications to us, including without limitation user queries, requests for customer support or copyright infringement or DMCA notices. Our use of this PII is solely to respond or otherwise address the e-mail communication from the user. We do not collect this PII for any other purpose and do not merge it with other PII or Non-PII (as defined below).
For certain advertising Products and Services and at the request and on behalf of a Client, Interpolls collects information supplied voluntarily by a user's submission which may include PII (e.g. User's name, email, etc.) through form fields filled by the user within our advertising Products delivered and displayed by our Platform on Third Party Websites. Following the collection by us or at the conclusion of the Client campaign, this PII is securely encrypted and delivered to the Client on whose behalf the information was collected. Interpolls does not re-use, re-sell, or distribute this PII to any other party and destroys this PII upon confirmation of receipt from the Client. The Clients' use of the PII is governed by and subject to their own privacy policies. Interpolls is not responsible for the Client or Third Party Websites' use of this voluntarily supplied data.
LEGAL BASIS AND PURPOSES FOR PROCESSING
If you are a user from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally process personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interest and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to process your request to exercise your rights regarding your personal data).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” heading below.
Please note that Interpolls’ Clients sometimes include their own (or their Affiliates’) ad-tags, pixels or similar technologies within advertisements that Interpolls serves to websites for those Clients. Interpolls does not control such collection or processing and we use reasonable efforts to require customers to treat such information in accordance with applicable laws and their own privacy policies.
Interpolls is not responsible for and cannot control the data collection and use practices of its Clients, Affiliates, or their partners. You should read the privacy notices of the websites you visit and the online services and interactive ads that you use to understand what information companies collect and how they use that information.
The cookies and Web beacons generated by our Platform can only be recognized and used by our Platform and are tailored to improve the quality of our Website and Products and Services. Cookies and Web beacons allow us to store user preferences, customize the content of our Products and Services displayed on a user's browser and record activities relating to user's online activities so that users will receive more relevant and less repetitive advertisements.
As described below, users also have the option to utilize an Opt-out cookie placed on the specific web browser to prevent our Website, web beacons, Products and Services and Platform from tracking and collecting user information by us. Please note that disabling cookies on the browser does not mean Users will no longer receive online advertisements from us. It means that Interpolls will no longer be able to deliver advertisements to that User that are tailored to his or her preferences or to limit the number of times the User see the same advertisement.
If Users would like to opt-out from having Interpolls collect user information and track online behavior in connection with our Website, Products and Services, and Platform, please click here to opt out .
When a user opts out, we will place an opt-out cookie on that user's specific web browser (i.e. Internet Explorer, Firefox, Safari, etc.). The opt-out cookie tells us not to collect user information and not to tailor our Website, Products and Services and Platform to the user's interests. Please note that if you delete, block or otherwise restrict cookies, or if you use a different web browser on the same computer or use a different computer, you may need to renew your opt-out choice. The opt-out cookie does not mean you will no longer receive online advertisements from us. It means that Interpolls will no longer be able to deliver advertisements to you that are tailored to your preferences or able to limit the number of times you may see the same advertisement.
When you voluntarily provide PII to complete registrations, enter promotions, contests or sweepstakes, or request products or services information from Clients and Third Party Websites, you are consenting to share the PII with Clients and their Affiliates so they can fulfill your request. Except in those instances where you voluntarily provide PII in connection with our Website or Products and Services to Client and Third Party Websites, we do not sell, rent or share PII collected on our Website with non-affiliated third parties without your consent. We may, however, share your PII with trusted third party contractors who provide services for us. These third party contractors are prohibited from using the information we provide for purposes other than performing services for us.
We may share Non-PII collected via our Products and Services or Platform with our Clients. Similarly, we may enhance the Non-PII collected via our Technology with Non-PII collected from our business partners. This information cannot be used to contact or identify any person individually.
User Information (PII and Non-PII) may also be disclosed by us in the following circumstances:
Special Note about Children: This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of 13, and provides important information regarding their rights under federal law with respect to such information.
Our Website is not intended for or directed to Users under the age of 13. Any user of our Website expressly represents and warrants that they are 13 years of age or older. Unless otherwise specifically indicated, Interpolls does not intentionally collect or store PII or Non-PII from users under the age of thirteen (13).
On certain occasions, Interpolls may administer some promotions or sweepstakes on behalf of its clients, which collect PII from children under the age of thirteen (13). In each such instance, Interpolls shall comply with the Children's Online Privacy Protection Act ("COPPA"), in the process of such promotion or sweepstakes, the collection of the information and in the subsequent use of the data collected. PII will not be collected from children under the age of thirteen (13) without parental consent in compliance with the COPPA guidelines.
Interpolls is a service provider as defined by CCPA.
The following additional disclosures for residents of California, as required under the California Consumer Privacy Act (“CCPA”):
Categories of personal information collected and disclosed for a business purpose. The personal information that Interpolls, a service provider as defined by CCPA, collects, or has collected from consumers in the twelve months prior to the effective date of this Disclosure, falls into the following categories established by the CCPA:
Right to Request Access to or Deletion of Personal Information: Upon request, we will provide you with information about whether we hold any of your personal information. You may request to access, update or deletion of your PII by emailing us at email@example.com.
No sale of personal information. Interpolls has never sold any personal information of consumers.
No Discrimination. Interpolls will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
If you are a California resident and would like to make such a request, please submit a written request to:
c/o Privacy Department
556 S. Fair Oaks Ave. #188
Pasadena, CA 91105
You have the following data protection rights:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contact Us” heading below.
In addition, if you are a resident of the European Economic Area, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time by exercising your opt-out options. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
You have the right to complain to a data protection authority about our collection and use of your personal information. You can file a complaint with our principal supervisory authority, the, or with a local authority.
As required by applicable law, including the Privacy Shield Framework, upon request, we will provide you with information about whether we hold any of your personal information. You may request to access, update or deletion of your PII by emailing us at firstname.lastname@example.org.
Interpolls uses industry standard security measures to protect the loss, misuse and alteration of the information from unauthorized access, use, modification, destruction, or disclosure. This includes, but is not limited to the use of firewalls and encryption. Nonetheless, due to the inherent dangers of the Internet, no data transmission over the Internet cannot be guaranteed 100% secure by Interpolls. Interpolls does not and cannot guarantee or warrant the protection and security of any user information against loss, misuse or alteration that users transmits on or through the Internet to our Website, Products and Services, or Platform, and users are hereby notified that this is done at the user's own risk.
c/o Privacy Department
556 S. Fair Oaks Ave. #188
Pasadena, CA 91105