Adswerve, Inc. (together with our affiliates and subsidiaries, “Adswerve,” “we,” “us,” or “our”) is committed to the fair and transparent processing of the personal information of our customers, consumers and website visitors. We also work hard to protect the personal information we collect and to ensure that you have the greatest possible control over your personal information.
If you have additional questions about privacy or information security, please contact us at firstname.lastname@example.org.
PERSONAL INFORMATION WE COLLECT
INFORMATION YOU PROVIDE
We may collect the following personal information that you provide through our Services or otherwise:
- Contact data, such as name, email address, mailing address, phone number, professional title, and organization affiliation;
- Transaction data, such as payment information, order history, and information associated with your transactions with us;
- Account data, such as username, account number, password, and other registration data;
- Preference data, such as your marketing preferences;
- Communications, including information associated with your inquiries to us and any feedback you provide when you communicate with us;
- Inferences relating to your use of the Services; and
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on the Services and other online sites and services, such as:
- Online activity data, such as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and basic data passed during text message transmission (including, but not limited to, data about the message content, photos, and files that you send or receive, and the message count/volume).
- Device data, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state or geographic area.
COOKIES AND SIMILAR TECHNOLOGIES
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Pixel tags, also known as web beacons or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of our marketing campaigns. For example, we may use pixel tags to collect information about your interactions with our email messages, such as the links you click on and whether you open or forward a message, the date and time of these interactions and the device you use to read emails.
- Session-replay technologies, which are third-party software services used to record a video replay of users’ interactions with a website, application, or other online service. The video replay may include users’ clicks, mouse movements, scrolls, typing, and other activity taken during the session. We may use session replay technologies for research and development purposes, such as to help us troubleshoot problems with the Services, understand how users interact with and use the Services, and identify areas for improvement.
THIRD PARTY SOURCES
We may receive personal information about you from other sources, such as our customers; companies that help provide our Services; data providers; business partners, such as joint marketing partners; and publicly-available sources, such as social media platforms. We may combine such personal information with information we have already collected about you.
Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
SENSITIVE PERSONAL INFORMATION
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., 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.
HOW WE USE PERSONAL INFORMATION
TO DELIVER THE SERVICES
We may use your personal information:
- To provide, operate, and improve the Services and our business;
- To create and maintain your account;
- To process and fulfill your orders, statements of work, and transactions, including to send you emails relating to the products and services we provide, and to provide other related communications;
- To respond to your inquiries or support tickets;
- To provide products and services you request;
- To operate, personalize, and improve the Services, including for analytics purposes;
- To enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; and
- For our other business purposes, such as payment processing and operational purposes.
RESEARCH AND DEVELOPMENT
We may use your information for research and development purposes, including to improve the Services, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
MARKETING AND ADVERTISING
We, our business partners and our third party advertising partners, may collect and use your personal information for direct marketing and interest-based advertising purposes.
- Direct Marketing. We may send you Adswerve-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
TO COMPLY WITH LAWS AND REGULATIONS
We use your personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
FOR COMPLIANCE, FRAUD PREVENTION, SAFETY
We may use your personal data and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
WITH YOUR CONSENT
In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
HOW WE SHARE PERSONAL INFORMATION
- Service Providers. Our vendors, consultants, agents, contractors, and other service providers that we use to help us operate the Services or support our business (such as Google LLC and other business partners, customer service providers, email service providers, IT, hosting, data management, marketing, and analytics providers).
- Our Customers. The organization you work for or that otherwise oversees your account on the Services.
- Business Transferees. Relevant participants in business transactions (or potential transactions) involving a corporate sale, merger, acquisition, reorganization, consolidation, or other transfer or disposition of all or part of our assets (including in connection with a bankruptcy or similar proceedings).
- Authorities, Law Enforcement and Others. Law enforcement, government authorities, and privacy parties, as we believe necessary for the compliance and protection purposes described above, such as pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of us, our users, or third parties.
- Professional Advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Advertising Partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
You can make the following choices with respect to your personal information:
- Opt Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at email@example.com. You may continue to receive service-related and other non-marketing emails.
- Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
- Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Declining to Provide Your Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
Adswerve is committed to protecting the security of the information we collect. Please note, no method of storage or transmission of data can be guaranteed or is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. You are responsible for maintaining the security of your username and password or other forms of authentication, limiting access to your devices and signing out of the Site after your sessions.
INTERNATIONAL DATA TRANSFER
Adswerve is headquartered in the United States and has service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
The Services are not directed at, and Adswerve does not knowingly collect personal information from individuals under the age of 18. If we learn that we have collected personal information from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
OTHER SITES AND SERVICES
The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
Attn: Legal Department
999 18th Street, Suite 2301N
Denver, CO 80202
SUPPLEMENTAL PRIVACY INFORMATION
The information below provides additional disclosures for individuals based upon their location or residency.
NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how we collect, use and share personal information of California residents in operating our business, and their rights with respect to that personal information. As used in this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. You have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Know/Access. You can request the following information about how we have collected and used your personal information:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, selling and/or sharing personal information.
- The categories of third parties with whom we disclose personal information.
- The specific pieces of personal information that we have collected about you.
- Deletion. You can ask us to delete the personal information that we have collected from you.
- Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information as described below, you can opt-out.
- Nondiscrimination. You are entitled to exercise the rights described above free without receiving discriminatory treatment.
You may submit a request to exercise your California privacy rights described above as follows:
- Right to know/access, correct, or delete. You may request to exercise your right to know/access, correct, or delete by emailing us or writing to us using the contact information listed above in the “Contact Us” section.
- Right to opt-out of the “sale” or “sharing” of personal information. Under California law, some of the data that we share with our advertising partners may qualify as a “sale” or “share” as defined under the CCPA. To exercise your right to opt-out, please email us at firstname.lastname@example.org or click here: . You may also broadcast the Global Privacy Control (“GPC”) signal when visiting our Services online. Note that due to technological limitations, if you visit our Services from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the link above to select your preferences or rebroadcast the GPC signal.
We will need to verify your identity to process your know/access, correction, and deletion requests and we reserve the right to confirm your California residency. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. If you wish to designate an authorized agent to make a request on your behalf, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
To the extent we collect sensitive personal information (as such term is defined under the CCPA), we only use or disclose it for purposes permitted under California law (e.g., to provide the Services, detect security incidences and prevent fraud, or to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
|CCPA Personal Information Categories||Examples (in reference to the section above titled “Personal Information We Collect”)|
|Individual Identifiers & Demographic Information||Contact data; device data|
|Commercial Information||Transaction data; preference data; communications; online activity data|
|Financial Information||Transaction data|
|Internet or Network Activity||Device data; online activity data|
|Professional or Employment Information||Contact data; transaction data; account data|
|Sensory Data||Communications (such as call recordings from our customer service line)|
|Inferences Drawn from Personal Information||Inferences|
Personal information disclosed for business purposes, “sold,” “shared.” We may disclose each of the personal information categories described above for business purposes, such as operational purposes, purposes related to providing you with the products and services you seek from us, and the other business purposes described in the “How We Use Personal Information” section above. Such business disclosures may occur to any of the third parties listed in the section above titled “How We Share Personal Information.”
The CCPA defines a “sale” as disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA.
Like many companies online, Adswerve uses services provided by Google and other advertising partners that track website visitor activity to help deliver interest-based ads to those visitors. Our use of some of these services may be classified under California law as a “sale” or “sharing” of your personal information to the companies that provide the services because they collect Internet or Network Activity information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. We may “sell” or “share,” and have “sold” or “shared” the following categories of personal information in the preceding 12 months to our advertising partners for purposes of advertising our Services and business and identifying new customers or potential customers: Individual Identifiers & Demographic Information, Commercial Information, and Internet or Network Activity. We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
Retention of personal information. We will retain each of the categories of personal information listed above for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
NOTICE TO EUROPEAN USERS
The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”).
|Processing Purpose||Legal Basis|
|To Deliver the Services||Processing is necessary to perform the contract governing our operation of the Site or the provision of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.|
|Marketing and Advertising||Processing is based on your consent where that consent is required by applicable law.
Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and showing you tailored relevant content.
|To Comply with Laws and Regulations||Processing is necessary to comply with our legal obligations.|
|With Your Consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.|
Retention. We will retain your personal data for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at email@example.com or at the mailing address listed above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at firstname.lastname@example.org for further information about any such transfers or the specific safeguards applied.
NOTICE TO NEVADA RESIDENTS
NOTICE TO VIRGINIA RESIDENTS
This section applies only to Virginia residents. It describes how we collect, use, and share personal information of Virginia residents when we act as a “controller” as defined under Virginia privacy law, and their rights with respect to their personal information. For purposes of this section, “personal information” means “personal data” as such term is defined under Virginia privacy laws but does not include information exempted from the scope of such laws.
Under Virginia law, you may request the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Access. You can request that we confirm whether we process your personal information and to access that personal information,
- Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Delete. You can ask us to delete personal information provided by or obtained about you.
- Port. You can request to obtain a copy of personal information that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
- Opt-out of targeted advertising. If we engage in “targeted advertising” according to Virginia law, you can opt-out.
You may request to exercise your Virginia privacy rights described above by emailing us at email@example.com. In addition, if you wish to opt-out of targeted advertising, you may click:
If we decline to take action on your request, you may appeal such refusal by sending us an email to firstname.lastname@example.org within a reasonable time period after we sent you our decision.
Last Updated: January 9, 2023