Updated as of May, 2018
PulsePoint is a member of the Network Advertising Initiative (“NAI”) and follows the NAI’s Code of Conduct, which outlines self-regulatory principles for personalized advertising. PulsePoint also complies with the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising.
WHAT TYPES OF INFORMATION DO WE COLLECT?
Non-Personally Identifiable Information (“Non-PII”)
We may automatically collect information that does not directly identify you personally but is linked to your computer or device. We collect this Non-PII from you in the normal course of operating our Websites. When you visit our Websites to browse, read or download information, we automatically collect information about your computer that your browser sends, such as your IP address, browser type and language, access times, pages visited, and referring website addresses. We do not link this information to anything that will allow us to identify users except to enforce compliance with our terms of service or to protect our rights or the rights of others. We may also collect Non-PII through “cookies” or “pixel tags” as explained below.
We may also collect information about your mobile device such as the type and model, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome, Safari), applications using our Websites, and identifiers assigned to your device, such as the iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.
We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (ISP) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.
In some countries, including countries in the European Economic Area (“EEA”), this information may be considered PII (as defined below) under applicable data protection laws. Please see our EEA Supplement for more information on the lawful grounds on which we process your information and data protection rights which you have if you are an EEA visitor.
Personally Identifiable Information (“PII”)
PII is information that allows us to directly identify and communicate with you as an individual, client, or prospective client. We may collect and retain PII that you provide through our Websites. This is typically business contact information, and may include: first and last name, physical address, email address, and phone number.
Such information may be voluntarily provided, for example when you register an account on any of the Websites or request more information through a form on the Websites. We may collect any other PII you provide through the Websites. The PII that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your PII.
HOW DO WE USE YOUR INFORMATION?
We use PII to respond to inquiries initiated by individuals, to provide services requested by such individuals, to alert businesses and prospective businesses to changes in services or features and to provide businesses and prospective businesses with requested information regarding our services. We may follow up with you directly using the PII that you have provided to us, including your email address, to discuss our products and services and to respond to inquiries.
We also use Non-PII to assess the use and operation of our Websites, such as how many users visited the Websites and the pages accessed. We use this information for our internal analytics and to help us tailor our Websites to our visitors and improve its performance.
WHAT INFORMATION DO WE SHARE?
We may also share PII and Non-PII under the following circumstances: (1) if required by law, such as by a court order, statute, regulation, rule, or through legal process; (2) in response to requests from federal, state, local, or foreign law and civil enforcement agencies, such as a search warrant, subpoena, or court order, or for law enforcement purposes; (3) in the event of a corporate transaction such as the sale of assets or all or most of PulsePoint’s assets or equity to another company; (4) in the event of a bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of our creditors; or (5) if we determine it necessary in connection with an investigation or in order to protect our legal rights.
Although the Non-PII that we share does not identify you directly, there is a risk that third parties who receive such information from us may be able to re-identify you through other information they gather.
Legal basis for processing PII (EEA visitors only)
If you are a visitor from the EEA, our legal basis for collecting and using the PII described above will depend on the PII concerned and the specific context in which we collect it. For further information relevant to EEA visitors, please click here
We are committed to following the NAI’s Code of Conduct and complying with the DAA’s Self-Regulatory Principles for Online Behavioral Advertising, which encourage consumer choice.
You may opt out of receiving ads from us by clicking the YourAdChoices Icon on ads that we send you, or by visiting the opt-out pages on the NAI website
and the DAA website
. Opting out does not prevent you from seeing ads; it simply means that we will no longer collect data for the purpose of providing you PulsePoint ads.
The DAA and NAI opt-out tools are cookie-based. They signal us so that we do not collect data online or deliver PulsePoint ads targeting you, and only affect the Internet/web browser on the computer where the cookies are installed. These opt out tools will only function if your browser is set to accept third-party cookies. If you delete an opt out cookie or all your cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is again reset on that browser. Opting out using one browser on one computer will not opt you out using any other browser on the same or another computer.
If you are using a mobile device, your mobile device may offer settings to limit or disable mobile apps from gathering certain information. You should check the settings for the app and your device. PulsePoint honors the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your device and select “limit ad tracking” (if Apple iOS) or “opt-out of interest based ads” (if Android).
In addition, if you would like to be removed from our client list for receiving informational and promotional materials, please contact us at email@example.com.
We use reasonable security measures to protect the data in our possession. However, no method of transmission or storage of data is 100% secure, and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether PII or Non-PII. To the extent we provide your PII to any third parties, we will request that they use reasonable security measures to protect your information.
SOCIAL MEDIA FEATURES
LINKS TO OTHER SITES
We do not knowingly collect information from or target end users under the age of 13. Our Websites are neither developed for nor directed at children. If we learn we have collected or received information from a child under 13 without verification of parental consent, we will endeavor to delete that information.
PulsePoint will retain your PII for 18 months after our last contact with you, and will retain individual Non-PII for 18 months after we observe a visit to our Websites (for example, such PII and Non-PII retained are name, email, IP address, device ID, etc.). Aggregated data about the use of our Websites may be retained for longer periods where we have an ongoing legitimate business need to do so.
We retain PII we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your PII, we will either delete or anonymize it or, if this is not possible (for example, because your PII has been stored in backup archives), then we will securely store your PII and isolate it from any further processing until deletion is possible.
If you would like to access, correct, update, or request deletion of your PII we have on file, you may submit such requests here
. Alternatively, you may email us at firstname.lastname@example.org
or write to PulsePoint Privacy Department, 360 Madison Avenue, 14th Floor, New York, New York, 10017. We may take reasonable steps to confirm your identity in an effort to prevent identity theft.
CROSS-BORDER DATA TRANSFERS
Our Website servers are based in the United States and operate under United States law. If you are located outside of the United States, the information we collect may be transferred to and processed in the United States and in other countries where the privacy laws may not be the same as the laws where you reside and, in some cases, may not be as protective. Additional considerations apply to the collection, use, and disclosure of information from individuals who live in the EEA.
DO NOT TRACK (“DNT”)
DNT is a privacy preference that you may set in certain web browsers. DNT is intended to allow you another method of informing websites and services that you do not want certain information about your website visits collected. We do not currently respond to DNT signals.
Questions and Comments
If you have questions about our Websites and your privacy, please e-mail email@example.com