Clipcentric Privacy Policy

Clipcentric, Inc. Privacy Policy

Notice: Our Privacy Policy has Changed

Effective Date: November 27, 2018

Contents

Introduction

Clipcentric, Inc. ("Clipcentric", "We", "Us", "Our") operates a creative management and distribution platform (the "Clipcentric Platform") that We provide, in conjunction with related services ("Clipcentric Services"), to advertisers, media publishers, advertising agencies, or other advertising related entities who have entered into a licensing agreement ("Platform Agreement") with Us ("Platform Customers").

Platform Customers may use this website (the "Clipcentric Site") as a point of entry to the Clipcentric Platform and Clipcentric Services for the purposes of (i) creating a variety of digital advertisements ("Clipcentric Ads"), (ii) preparing the Clipcentric Ads for distribution to a variety of websites, applications or other media properties that they own or operate, or that are owned or operated by third parties with whom they have agreements ("Customer Distribution Partners"), (iii) obtaining reporting data regarding the performance of Clipcentric Ads, and (iv) administering other aspects of their business relationship with Us.

When an individual visits or is exposed to a Customer Distribution Partner, that individual may then be shown a Clipcentric Ad (in this case, the individual is an "Ad Viewer").

As part of the Clipcentric Platform and Services, We may also make a variety of media content (e.g. video clips, music tracks, photographs and other digital graphics) available to our Platform Customers for use in their Clipcentric Ads. Some of this content may be provided to us by third party contributors with whom we have contractual agreements ("Content Contributors"). For the purposes of this privacy policy ("Privacy Policy"), provisions regarding Platform Customers shall also apply to Content Contributors.

Prospective Platform Customers or those seeking information on Our products and services may visit the Clipcentric Site to learn more about Us ("Site Visitors").

We take the privacy concerns of Clipcentric Platform Customers, Ad Viewers, and Site Visitors seriously. This Privacy Policy governs Clipcentric's online information collection and use for: (i) Platform Customers, (ii) Site Visitors, and (iii) Ad Viewers.

This Privacy Policy also applies to any information an individual may provide to Clipcentric or that Clipcentric may collect offline and/or through other means (for example, via telephone, or through the mail).

This Privacy Policy describes what information We collect, how it is used and the choices available regarding Our use of information that We collect, including personal information, and how you can access and update this information.

Data Protection Legislation; Data Controllers, Processors and Legal Basis

Laws regarding the collection and use of Personal Data may vary for individuals from different geographical regions. Clipcentric adheres to all applicable legislation, which may include the US FTC Act, the US Children's Online Privacy Protection Act (COPPA), the EU General Data Processing Regulation (GDPR), the Federal Data Protection Act of 19 June 1992 (Switzerland), the Australian Privacy Act 1988 (AUS Privacy Act), and other similar legislation (collectively "Data Protection Legislation").

Some Data Protection Legislation delineates entities that determine the purpose, conditions and means of processing Personal Data ("Data Controllers") from entities that process Personal Data on behalf of a Data Controller ("Data Processors").

Clipcentric may act as a Data Controller or a Data Processor, depending on the type of information collected, the method of collection, and the use of the information. Throughout this Privacy Policy, We indicate our role as a Data Controller or Data Processor wherever We describe Our methods and use for handling Personal Data.

Clipcentric's legal basis for collecting and utilizing Personal Data of individuals, including individuals from the European Economic Area (EEA), will depend on the type of Personal Data concerned and the specific context in which it is collected.

We will not intentionally collect Personal Data from you unless (a) you have provided your consent to do so, (b) We need the Personal Data to deliver the Clipcentric Platform or provide the Clipcentric Services, (c) We have a legal obligation to collect Personal Data from you, or (d) where the collection and processing of the Personal Data is in Our or a third-party's legitimate interests, which shall not be overridden by your data protection interests or fundamental rights and freedoms.

Where We rely on your consent to process your Personal Data, you have the right to withdraw or decline your consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing based on consent prior to its withdrawal.

Should you have additional questions or require further clarification concerning the legal basis for which We collect and use your Personal Data, or if you wish to modify your consent preferences or request for us to modify, delete or transfer your Personal Data, please contact us at privacyrequest@clipcentric.com.

Classification of Information

The information collection and use policies described in this Privacy Policy refer to two types of information that may be collected from natural people: (i) Non-Personal Data and (ii) Personal Data, defined as follows:

Non-Personal Data

Non-Personal Data is any information that is not, on its own, used to contact, identify or precisely locate an individual. Examples of Non-Personal Data include browser type (e.g., Netscape or Internet Explorer), operating system (e.g., Macintosh or Windows).

Personal Data

Personal Data generally considered to be information that can be used to directly or indirectly contact, identify or precisely locate an individual, however, the explicit definition of what constitutes Personal Data may vary depending on where you live. Examples of Personal Data may include: name, email address, postal address, telephone number, social security number, precise device location data, government issued-identifier, unique user ids, and credit card or other financial account numbers. To the extent that the Personal Data of an individual is collected, stored or used, that individual is known as a "Data Subject". In some jurisdictions, the IP Address from which a Data Subject accesses an online service may be considered Personal Data.

Technologies Related to Information Collection and Storage

To assist readers with understanding some of the information collection technologies referred to in this Privacy Policy, brief descriptions are included here, along with links to resources for more information. This list may not be complete and some of these collection technologies may not apply to you. Details on how these technologies are used to collect information may depend on whether you are (i) a Platform Customer, (ii) a Site Visitor, or (iii) an Ad Viewer, while some of the below details apply to all individuals. These details are described in following sections:

Html Forms

Html Forms are input fields where individuals may enter information that is collected by the host application. Html forms may request Personal Data, and it is up to the individual whether or not to enter such information. For example, Html forms are often used for user registrations and "Contact Us" information requests, where the individual supplies contact information in order to be contacted by email, telephone or other means.

Http Cookies

Http Cookies (also known as browser cookies, or simply cookies) are small files that are stored on a user's computer via a web browser. They are designed to hold a modest amount of data specific to a particular browser (e.g. Firefox) and website (i.e. domain). Cookies are used because they are a convenient way of carrying information from one session on a website to another, or between sessions on related websites. A cookie consists of (i) a name, by which it is referenced, (ii) the domain to which it is attached, i.e. facebook.com or tr.clipcentric.com, (iii) a number of key/value pairs, such as loggedin=yes or gender=male, and (iv) its duration, or how long before the cookie is deleted, e.g. when the browser window is closed, 90 days or forever. You can view or delete any cookies that are stored by your browser using browser tools.

Server Log Files

Server Log Files contain a list of requests received by a webserver or delivery network. Almost all the websites you visit, or any of the applications you access online generate log files that may include visitor IP Addresses, operating systems, browsers type, referring/exit pages, ISP and device information. This information is typically used to monitor site/application traffic, usage patterns and trends, timestamps and clickstream data, as well as to troubleshoot errors and problem areas.

IP Address

An IP Address is a fundamental identifier used for communication over the internet. It is a number that is usually automatically assigned to the computer that you are using by your internet service provider (ISP) or by another organization. When your browser makes any request over the internet, your IP Address must be included with the request so that the server processing the request knows where to send the reply. Upon the server receiving such a request, the related IP Addresses are commonly stored in Server Log Files. While an IP Address, by itself, cannot in most cases identify you personally, when combined with other information, your IP Address could be used to identify the computer you are using. Your IP Address may also be used to estimate your Imprecise Device Location. In some jurisdictions, your IP Address alone may be considered Personal Data, while in other jurisdictions, it may be considered Non-Personal Data.

User Agent Strings

User Agent Strings are a series of characters automatically sent with your internet requests that provide information designed to enable effective internet communications such as the operating system and browser you used. User Agent Strings also commonly include information the webpage you were on when the request was made. User Agent Strings are commonly stored in Server Log Files. Similar to an IP Address, a User Agent String, by itself, does not identify you personally. However, when combined with other information, a User Agent String might be used to construct a Unique Id, which could be used to identify the computer originating a request.

Unique IDs

Unique IDs are identification numbers or strings that are used to identify a particular user or device. Unique IDs may be created from elements of Server Log Files, including IP Addresses and User Agent Strings, or be passed directly from one party to another. Unique IDs may be truly unique to a user, browser, device or platform, or may rely on statistical methods to correlate users, browsers, devices or platforms with user activity.

Tracking Pixels

Tracking Pixels (also known as Clear Gifs, Web Beacons) are invisible 1x1 pixel images that are requested from a remote server via a url that typically contains small strings of encoded information, which may in part be determined by Embedded Scripts and Http Cookies. When a Tracking Pixel is requested from a server, that server may decode and process this information, for example, storing it to Server Log Files for future analysis.

Embedded Scripts

Embedded Scripts are programming code snippets that, in addition to other functionality, may be designed to collect information about your interactions with a website or website component (including advertisements), such as the links you click on. Embedded Scripts may set or read Http Cookies, use Tracking Pixels or employ virtually any other information collection technology. Embedded Scripts may be temporarily downloaded onto your device from an application's web server, or the server of a third party provider. An Embedded Scripts is active only while you are connected to the website containing the Embedded Scripts, and is deactivated or deleted thereafter.

Local Storage

Local Storage is another method of storing information locally on a user's computer, via a web browser. Storing information using Local Storage is similar to using a Http Cookie, but allows for the storing of a greater amount of data with improved performance and increased security, as no information is transferred from the browser to a web server. Local Storage may be cleared at the end of a browser session (Session Storage), or be stored indefinitely (until removed by an application or end-user). Like Http Cookies, Local Storage is per origin (per domain and protocol). All pages, from one origin, can store and access the same data. Therefore, the concepts of First Party Local Storage and Third Party Local Storage exist, just like with Http Cookies. For more information, please refer to https://www.w3.org/TR/webstorage/.

Local Shared Objects

Local Shared Objects, also known as Flash® cookies, is a method of storing information utilizing the Adobe Flash® player. Flash cookies are different from Http Cookie because of the amount of, type of, and how data is stored. For example, Local Shared Objects can be stored or retrieved for a particular domain whenever a user accesses a page containing a Flash application. While this "same domain restriction" is similar to that of Http Cookie, Local Shared Objects are persistent across sessions using different browsers (e.g. Chrome and MSIE). Local Shared Objects are commonly used to store preferences, track application data (such as game stats) or track a user's activity within the domain.

Click-through Redirects

A Click-through Redirect is a method for a third party to track a click on an advertisement. Rather than the ad click immediately resulting in your browser opening the target webpage, your request is "relayed" or "redirected" through an intermediary webserver, which can then store information pertaining to the click-through in Server Log Files. The intermediary webserver may set a Http Cookie during a Click-through Redirect.

Iframes

Iframes are a web technology that enable a nested browsing context, effectively enabling one HTML page to be embedded in another HTML page (see https://www.w3.org/TR/html5/semantics-embedded-content.html#the-iframe-element). When an individual visits a webpage, it may not be obvious that some of the content on that webpage is contained in an Iframes, and that such content may be requesting and receiving information from servers operated by a party other than that of the parent webpage ("Third Party Servers"), using their own domain. This is important because some information collection and use methods are restricted to exchanging information only on the same domain, e.g. Http Cookies or Local Storage, and Iframes may allow these methods to be used by both the parent webpage domain and the Third Party Servers domain. Additionally, technologies, such as Web Messaging (see https://www.w3.org/TR/webmessaging/) exist where information can be shared between domains, effectively circumventing 'same domain' restrictions. In fact, if a third party is serving content to an Iframe, especially 'friendly iframes' or iframes that have unrestricted access to the content of the parent webpage, they may technically employ virtually any information collection method.

Precise Device Location

Precise Device Location of an internet connected device is available via the W3C Geolocation API Specification (see https://dev.w3.org/geo/api/spec-source.html). Common sources of location information include Global Positioning System (GPS) and location inferred from network signals such as IP Address, RFID, WiFi and Bluetooth MAC addresses, and GSM/CDMA cell IDs, as well as user input. While no guarantee is given that the API returns a device's actual location, the availability of accurate location information may be sufficient for your Precise Device Location to be considered Presonal Data". In addition to default operating system and/or browser restrictions, it is the policy of Clipcentric that your Precise Device Location will not be determined without your explicit consent, e.g. responding "yes" to a prompt asking permission to use your current location.

Imprecise Device Location

Imprecise Device Location of an internet connected device may be estimated by comparing the device IP Address with a database of IP Addresses correlated with geographic location (also known as an IP Geolocation Database). The accuracy of Imprecise Device Location is typically at the postal code level or less. For example, one of the more popular commercial IP Geolocation Databases claims to provide as high as a 90% success rate for city-level location within 50km of the actual device location.

Policy for Platform Customers

Clipcentric's policy for the collection and use of information regarding (i) Platform Customers and (ii) the employees and agents that Platform Customers authorize to use the Clipcentric Platform and Clipcentric Services on their behalf ("Authorized Users") is, in part, governed by a Platform Agreement executed between Clipcentric and the Platform Customers.

To the extent that Platform Customers provide Clipcentric with Personal Data of Authorized Users or other individuals, the Platform Customer is the Data Controller of this Personal Data, and Clipcentric is a Data Processor as authorized by a Platform Agreement. Examples of the types of data that Clipcentric may process on behalf of Platform Customers include an individual's name, address, phone number, email address, user id and job title.

As a Data Controller, Clipcentric may also automatically collect and store other Personal Data from Authorized Users as they access the Clipcentric Platform and Clipcentric Services (i) as required to operate the Clipcentric Platform and Clipcentric Services, (ii) to analyze usage patterns and improve our service, and (iii) to detect and troubleshoot technical errors. This Personal Data may include IP Addresses, Unique IDs, elements from User Agent Strings and other Non-Personal Data that may be correlated with Personal Data, including Personal Data for which We are a Data Processor and have the authority to use in this manner.

Policy for Site Visitors

Information Collection Methods and Use by Clipcentric

Personal Data

Automatically Collected Data
As is the case for most websites, when you visit the Clipcentric Site, We gather certain information automatically and store it in Server Log Files. This information includes IP Addresses, which in some jurisdictions may be considered Personal Data, and therefore may be subject to Data Protection Legislation. After collection, We only use your IP Addresses for the internal purposes of detecting and preventing fraud or unauthorized access and maintaining the security of our systems. Access to Server Log Files containing IP Addresses is restricted to authorized employees and agents of Clipcentric. After an initial period not to exceeding 24 hours, Server Log Files containing IP Addresses are protected by encryption technologies and archived to secure storage facilities.
Data you Knowingly Submit
Clipcentric does not collect any other Personal Data of Site Visitors before, during or after your visit to the Clipcentric Site other than what you voluntarily supply to Us via Html Forms (e.g., submitting information through the Contact Us and/or registration forms). This information may include name, address, billing address, email, phone number and company information. When Personal Data is provided by you directly to Us in this manner, Clipcentric is the Data Controller of the Personal Data, which We use solely for the purposes identified at the point of contact, such as to convey requested product or service information, assess the needs of your business to determine suitable products, respond to customer service requests and improve the Clipcentric Site. We may store this information in email files, both on Our server and on the local computer file systems of authorized Clipcentric employees. We may transfer this information to Data Processors who have a contractual obligation to protect the information and adhere to applicable Data Protection Legislation. For example, We may transfer this information into customer relationship management platforms.

Non-Personal Data

We also collect other information automatically from Site Visitors and store it in Server Log Files, including User Agent Strings. We use this information, which We do not link to Personal Data or otherwise use to identify individual users, to analyze trends, to administer the Clipcentric Site, to track users' movements around the Clipcentric Site and to gather aggregated demographic information about Our user base as a whole.

Clipcentric Ads are displayed in the Clipcentric Site for demonstration purposes to prospective Platform Customers so that they may learn the types of ads our products and services allow them to create and distribute. If you view portions of the Clipcentric Site that contains these Clipcentric Ads, you will also be subject to our Policy for Ad Viewers.

We do not link any of the Non-Personal Data described in this section to any Personal Data unless you are logged in as an Authorized User of a Platform Customer, operating under a Platform Agreement, in which case you are also subject to our Policy for Platform Customers.

Information Collection Methods and Use Third Parties

Analytics Partners

We may use third party analytics partners (such as Google Analytics) to inform us of traffic patterns, so that we may improve the effectiveness of Our Clipcentic Site content ("Site Analytics Partners"). We do not pass any Personal Data to Site Analytics Partners, however, Site Analytics Partners may employ Tracking Pixels or Embedded Scripts, which results in Site Analytics Partners receiving the IP Address of Site Visitors. We only utilize Site Analytics Partners where IP Address Anonymization techniques are employed, such as setting the last octet of IPv4 user IP Address and the last 80 bits of IPv6 addresses. Note that IP Address Anonymization techniques only affect the storage and processing of IP Addresses, not the transfer.

Site Analytics Partners may also use Http Cookies and/or Local Storage. For a description of how our current Site Analytics Partner, Google Analytics, uses Http Cookies, please refer to the website "Google Analytics Cookie Usage on Websites" at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. For more general information about Google Analytics, including how you can control the information collected by Google, please refer to the website, "How Google uses data when you use our partners' sites or apps" at http://www.google.com/policies/privacy/partners/.

Links to Third Parties

The Clipcentric Site and Clipcentric Services may include links to other web sites whose privacy practices may differ from those of Clipcentric. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web sites you visit.

Policy for Ad Viewers

Information Collection Methods and Use by Clipcentric

Personal Data

Automatically Collected Data
In the course of delivering a Clipcentric Ad to you, Clipcentric automatically collects and stores your IP Address in Our Server Log Files. Clipcentric is a Data Controller of such automatically collected information. Platform Customers and their Customer Distribution Partners where you encounter Clipcentric Ads may also be considered Data Controllers of this information, as their respective agreements and policies may indicate. Clipcentric utilizes third party hosting companies to store and process this automatically collected data, and Clipcentric requires such Processors to comply with all applicable Data Protection Legislation.

In some jurisdictions, your IP Address may be considered Personal Data, and may therefore be subject to Data Protection Legislation. After collection, We only use your IP Address for the internal purposes of detecting and preventing fraud or unauthorized access and maintaining the security of Our systems. Access to Server Log Files containing IP Addresses is restricted to authorized employees and agents of Clipcentric. After an initial period not to exceeding 24 hours, Server Log Files containing IP Addresses are protected by encryption technologies and archived to secure storage facilities.

We may also use your IP Address on-the-fly to estimate your Imprecise Device Location. In this case, your IP Address is passed directly from your internet browser or application to Our server's temporary memory by an Embedded Script. We do not store your IP Address when collected in this manner, or link it to any other information other than comparing it to a geolocation database after which the IP Address is promptly deleted from temporary memory.
Data you Knowingly Submit
Some Clipcentric Ads may request your Precise Device Location, for example, when displaying your location on a map relative to nearby stores. If you provide your explicit consent, your Precise Device Location is passed directly from your internet browser or application to Our server's temporary memory by an Embedded Script. Our servers may respond to this information by returning a customized ad experience.

Non-Personal Data

Other than your IP Address, and in some cases your Precise Device Location received after your explicit consent (both as described above), We do not collect or store any Personal Data from Ad Viewers. However, We do collect certain Non-Personal Data regarding your exposure to a Clipcentric Ad, such as your browser type, the server your computer is logged into, the type of computer operating system you use, and whether and how individuals using your internet browser or similar applications have responded to the ad delivered. The Non-Personal Data that We collect is used for the purpose of customizing the ads delivery and measuring the effectiveness of these ads on behalf of Our Platform Customers.

We collect your User Agent String and store it in Our Server Log Files. We use this information to control how Clipcentric Ads are served to particular devices or platforms, and to provide Our Platform Customers with information on the device types and platforms Ad Viewers used while viewing Clipcentric Ads.

We may use Embedded Scripts to generate and use other anonymous information, which may be passed to Our servers by Tracking Pixels where it is then stored in Server Log Files. We use this information to anonymously measure the efficacy of Clipcentric Ads and to create Clipcentric Ad campaign performance reports.

At the discretion of Platform Customers. Clipcentric Ads may use Cookies and/or persistent Local Storage to keep track of how many times an Ad Viewer has seen a particular Clipcentric Ad in a particular timeframe. This information may be used to customize how Clipcentric Ads are rendered to Ad Viewers. For example, We may display an alternate ad experience to Ad Viewers based on whether or not Ad Viewers have already seen the same Clipcentric Ad. We do not store any Personal Data in these Cookies or Local Storage, nor do We link the information We store in Cookies or Local Storage to any Personal Data. If a Platform Customer elects for their Clipcentric Ads to use Cookies or Local Storage, they may also determine whether to use first party or third party Cookies or Local Storage. Third party Cookies and Local Storage allows Clipcentric to keep track of how many times an Ad Viewer has seen a Clipcentric Ad across multiple publishers or publish domains. When Cookies are used in this way, they will expire within 2 years. When Local Storage is used, it may remain in your browser for an extended period of time. Clipcentric Ads include a consent mechanism, where Platform Customers or their Customer Distribution Partners, acting as Data Controllers, may indicate to Clipcentric whether or not using Cookies and/or Local Storage is authorized. Below is an example of the type of anonymous information that is stored in Cookies and Local Storage for these purposes:



We use Click-through Redirects to allow Us to track click activity on Clipcentric Ads, or to allow Our Platform Customers and their analytics partners (or their clients and their client's analytics partners) to track such activity. Click-through Redirect activity is stored in Our Server Log Files, and is analyzed in conjunction with other information to produce reports on the effectiveness of Clipcentric Ads for our Platform Customers.

Information Collection Methods and Use by Third Parties

Customer Custom Content

At the sole discretion of a Platform Customer, Clipcentric Ads may include content developed by or on behalf of the Platform Customer or otherwise included within a Clipcentric Ad ("Customer Custom Content"). For example, Platform Customers may include full Html documents within an Iframe embedded in a Clipcentric Ad, load a remote Embedded Script, direct the Clipcentric Ad to set an Http Cookie, use a third party Tracking Pixel, or utilize Click-through Redirects.

Clipcentric is largely unaware of a Platform Customer's use of Customer Custom Content, and We do not handle, process, monitor or control any information collected as a result of Customer Custom Content ("Customer Custom Content Data Proceeds"), which may contain Personal Data, nor does Clipcentric know in advance or control the Customer Distribution Partners of a Platform Customer. Platform Customers are bound by their Platform Agreement with Clipcentric to adhere to applicable Data Protection Legislation with regards to Customer Custom Content Data Proceeds, and alone or in conjunction with their Customer Distribution Partners, have taken responsibility as independent Data Controllers of such information.

Platform Customers may pass information into Clipcentric Ads for the purposes of displaying customized ad experiences to Ad Viewers. In some cases, this information may be transferred to Clipcentric servers for processing. Platform Customers are obligated by their Platform Agreements to comply with applicable Data Protection Legislation with respect to information transmitted to Clipcentric in this manner. In this instance, Clipcentric is the Data Processor, and processes such information only as authorized by the applicable Data Controller.

Customer Selected Third Party Widgets

At the sole discretion of a Platform Customer, Clipcentric Ads may include embedded social media features (such as an embedded Facebook page or Twitter timeline) or features derived from third party APIs (such as Google Maps or YouTube Videos), collectively known as "Customer Selected Third Party Widgets".

While features of Clipcentric Platform and Clipcentric Services facilitate the inclusion of Customer Selected Third Party Widgets into Clipcentric Ads, Clipcentric does not handle, process, monitor or control any information collected as a result of Customer Selected Third Party Widgets ("Customer Selected Widget Data Proceeds"), which may contain Personal Data, nor does Clipcentric know in advance or control the Customer Distribution Partners of a Platform Customer.

Platform Customers are bound by their Platform Agreement with Clipcentric to adhere to applicable Data Protection Legislation with regards to Customer Selected Widget Data Proceeds, and alone or in conjunction with their Customer Distribution Partners and/or the third parties that host the Customer Selected Third Party Widgets, have taken responsibility as independent Data Controllers of such information.

As a service to readers, links to the privacy policies of some entities providing Third Party Widget APIs are listed below. Clipcentric does montior or control the extent to which these entities adhere to their privacy policies, nor can we assure that these links will point to the most current versions of their policies:

Transfer of Information to Third Parties

In some cases, We may pass an individual's Precise Device Location (see Policy for Ad Viewers » Information Collection Methods and Use by Clipcentric » Personal Data » Data you Knowingly Submit) directly from Our server's temporary memory to a third party in order to provide the Clipcentric Services. For example, We may pass this information to Google Maps in order to display nearby stores by means of the Google Maps API. In this example, Clipcentric and Google act as independent Data Controllers of the information, each individually determining the purposes and means of its processing.

Except for this use, and otherwise as described in Other Clipcentric Information Collection and Use Policies » Sharing of Information, We do not collect any Personal Data on behalf of third parties, nor do We transfer any of your Personal Data to third parties.

We may transfer Non-Personal Data to third parties in the form of ad performance reports and industry benchmarks. This information may include elements from User Agent Strings, Server Log Files, Local Storage and Http Cookies.

Other Clipcentric Information Collection and Use Policies

Cookie Opt-Out

Platform Customers may direct Clipcentric Ads to use third party Cookies or Local Storage (i.e. storage attached to Clipcentric domains). No Personal Data is included in this storage, as described in section: Policy for Ad Viewers » Information Collection Methods and Use by Clipcentric » Non-Personal Data

We provide an "opt out" mechanism so that Ad Viewers may "opt out" of these Cookies and Local Storage. To opt-out, click the "Opt-Out" button below. If you later change your mind after opting out (for example, because you decide that it is better to be shown a different advertising experience the second time you see a Clipcentric Ad), you may opt back in by clicking the "Opt-In" button below.



You can also manage how your browser handles Cookies and Local Storage by following directions provided in your internet browser's "help" directory.

Note that this opt-out mechanism relies on a Clipcentric Http Cookie (named 'notrack'), so if you delete, reject or block this cookie, it may negate the functionality of our opt-out mechanism.

Preventing Malicious Activity; Black Lists; Consent Logging

As a Data Controller, we may collect and store certain information that is known or suspected to be related to malicious activity, and which may used for our legitimate interest of reducing fraud, data tampering, or unauthorized access to Clipcentric systems ("Information Black Lists"). Information Black Lists may be stored in less secure environments in order to enable a real-time comparison of new data against a list of known or suspected bad actors. Information Black Lists may include IP Address, Unique IDs, elements from User Agent Strings, or other similar information. We may store and process this information without explicit consent on the legal basis that preventing fraud and malicious activity is in the legitimate interest of Clipcentric and our partners.

We may also store information we require to track an individual's consent status with respect to Clipcentric's collection and/or use of Personal Data. This information may include an individual's name, address, email address or telephone number.

Sharing of Information

We will only share Personal Data with third parties in the ways that are described in this Privacy Policy. We do not otherwise sell, rent or distribute Personal Data to third parties.

We may provide Personal Data, for which We are a Data Controller or authorized Data Processor, to companies that provide services to help Us with Our business activities such as hosting the Clipcentric Site, Clipcentric Platform and Clipcentric Services or sending emails. These companies are authorized as Data Processors to use your Personal Data only as necessary to provide these services to Us and are contractually obligated to keep your information confidential and comply with applicable Data Protection Legislation regarding the processing of any Personal Data.

We may also disclose Personal Data:
  • as required by applicable law, such as to comply with a subpoena, or similar legal process
  • when We believe in good faith that disclosure is necessary to protect Our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, including to meet law enforcement or national security requirements
  • if Clipcentric is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case you will be notified via email and/or a prominent notice on the Clipcentric Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
  • to any other third party with your prior consent to do so. We have potential liability in the event of unlawful onward transfers of Privacy Shield data to third party agents (see Self-Regulatory Frameworks, below)

How we secure your Personal Information

Clipcentric uses reasonable administrative, technical, personnel and physical measures to safeguard Personal Data in Our possession against loss, theft and unauthorized use, disclosure or modification. However, no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you elect to share your Personal Data. We cannot guarantee that only authorized persons will view your Personal Data. We cannot ensure that information you share on the Clipcentric Site and/or through the Clipcentric Platform and Services will not become publicly available. We cannot guarantee that essential Clipcentric Data Processors will not be exposed to a data breach. We are not responsible for third party circumvention of any privacy settings or security measures on the Clipcentric Site or through the Clipcentric Platform and Services. You can reduce some of these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

In the event of a data breach that exposes Personal Data, or in Clipcentric's reasonable judgement threatens to expose Personal Data, Clipcentric shall comply with the notice provisions of applicable Data Protection Legislation.

User Access and Choice

You may access, correct, update, amend, or ask to have Personal Data that We store about you removed, deleted or transferred to you or a third party by making a change in the Clipcentric "Customer Account" settings page, by emailing a request Our customer support at support@clipcentric.com or by contacting Us by telephone or postal mail at the contact information listed below. We will respond to your requests within 30 days.

We will retain your information for as long as your account is active or as needed to provide you with the Clipcentric Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce Our agreements. Personal Data that We process for any purpose shall not be kept for longer than is necessary for such purpose, however, We may retain Personal Data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also store some Personal Data in Our secure, non-production backup files provided that induvial consent choices will be honored in the event that any backup files containing Personal Data are restored to a production environment in a disaster recovery scenario. Clipcentric does not store any sensitive Personal Data such as credit card information, social security numbers, and the like, in its backup files.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacyrequest@clipcentric.com.

Clipcentric as a Data Processor of Other Customer Controlled Data

Customer Custom Content may also include Personal Data that may be displayed to Ad Viewers ("Customer Controlled PII"). For example, Customer Custom Content may contain the name and contact information of a sales representative at the company being promoted by a Clipcentric Ad. Clipcentric has no control with respect to individuals whose information is included in Customer Controlled PII, and Clipcentric is largely unaware of whether Customer Controlled PII is actually being used as part of Customer Custom Content, or the methods of such use. The Clipcentric Platform Customer is either the Data Controller of the Customer Controlled PII, or, if the Clipcentric Platform Customer is a Data Processor of the Customer Controlled PII, (i) the methods and use of the Customer Controlled PII within the Customer Custom Content, and (ii) Clipcentric's appointment as an additional Data Processor have been authorized by the relevant Data Controller consistent with applicable Data Protection Legislation.

Children's Privacy

The Clipcentric Site is not intended for children under 13 years of age. You must be at least 13 years old to use the Clipcentric Site and/or Clipcentric Platform and Services. We do not knowingly collect Personal Data from any child under 13 years of age.

Please advise Us if you are aware of our having received Personal Data from someone under 13, in which case We will take appropriate steps to delete it.

Note that Clipcentric Ads may contain Social Media Features and Third Party Widgets and/or Custom Ad Components as previously described, and Clipcentric does not monitor or control the information collected through these elements. If you believe Personal Data from someone under 13 has been collected in violation of applicable law, you must contact the advertiser or publisher responsible. We may be able to assist you in determining if the Clipcentric Ad was designed in such a way that the collection of Personal Data was possible.

California Privacy Rights

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents to request and obtain from Clipcentric once a year, free of charge, information about the personal information (if any) Clipcentric disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which Clipcentric shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request, with information about where you saw the Clipcentric Ad, in writing to: Clipcentric, Inc., Privacy Information Request, 915 Broadway Suite 2E Albany, NY 12207.

Self-Regulatory Frameworks

EU-US and Swiss-US Privacy Shields

Clipcentric complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Clipcentric has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov

With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Clipcentric is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Clipcentric's accountability for Personal Data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Clipcentric remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the Principles, unless Clipcentric proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Clipcentric commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Clipcentric by email at privacyrequest@clipcentric.com or the contact information found below.

Clipcentric has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Transfer to Agents

Except as described in this Privacy Policy, Clipcentric will transfer EU and Swiss Data only to those third parties who have provided assurances that such data will be treated consistently with the requirements of this Privacy Policy. In particular, except as described in this Privacy Policy, We will transfer EU and Swiss Data only to third parties who are contractually obligated to comply with the principles of the EU-US and Swiss-US Privacy Shields, respectively. In the event that Clipcentric has knowledge that any third party to whom it has transferred EU or Swiss Data has used or disclosed EU or Swiss Data in a manner contrary to this Privacy Policy, Clipcentric will take reasonable steps to prevent or stop such use or disclosure.

Changes to This Policy

We may update this Privacy Policy at any time. If We make any material changes, We will revise the "Effective Date" on the Privacy Policy. Any such amendment to this Privacy Policy will be effective upon our posting of the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Clipcentric Site or Clipcentric Platform and Services constitutes your agreement to this Privacy Policy.

Regulatory Oversight

Clipcentric is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Questions Regarding Privacy

If you have any questions, comments or concerns about this Privacy Policy or Clipcentric's privacy practices, to update or delete your Personal Data, or for assistance removing Http Cookies or other information storage, please contact Clipcentric at:

privacyrequest@clipcentric.com
M-F 9:00a to 5:00p ET (800) 653--5604

Clipcentric, Inc.,
Privacy Information Request
915 Broadway Ste 2E
Albany, NY 12207