Privacy Policy


Address:

Clickbooth.com, LLC

IntegraClick Professional Park East Building

Suite 210

5901 North Honore Avenue

Sarasota, FL 34243-2632

 

Phone: 941-483-4188

Toll Free: 866-TOP-OFFERS (866-867-6333)

 

We can be reached via e-mail at compliance@integraclick.com or you can reach us by telephone at 941.483.4188.

For each visitor to our Web page, our Web server automatically recognizes only the consumer's domain name but not the e-mail address (where possible).

 

We collect only the domain name, but not the e-mail address of visitors to our Web page, the e-mail addresses of those who post messages to our bulletin board, the e-mail addresses of those who communicate with us via e-mail, the e-mail addresses of those who make postings to our chat areas, aggregate information on what pages consumers access or visit, user-specific information on what pages consumers access or visit, information volunteered by the consumer, such as survey information and/or site registrations.

 

The information we collect is used to improve the content of our Web page, used to customize the content and/or layout of our page for each individual visitor, used to notify consumers about updates to our Web site, shared with other reputable organizations to help them contact consumers for marketing purposes.

 

With respect to cookies: We use cookies to store visitors preferences, record session information, such as items that consumers add to their shopping cart, record user-specific information on what pages users access or visit, alert visitors to new areas that we think might be of interest to them when they return to our site, record past activity at a site in order to provide better service when visitors return to our site, ensure that visitors are not repeatedly sent the same banner ads, customize Web page content based on visitors' browser type or other information that the visitor sends.

 

If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the above address, writing to us at the above address.

 

From time to time, we make the e-mail addresses of those who access our site available to other reputable organizations whose products or services we think you might find interesting. If you do not want us to share your e-mail address with other companies or organizations, please let us know by calling us at the number provided above, writing to us at the above address.

 

From time to time, we make our customer e-mail list available to other reputable organizations whose products or services we think you might find interesting. If you do not want us to share your e-mail address with other companies or organizations, please let us know by calling us at the number provided above, writing to us at the above address.

 

If you supply us with your postal address on-line you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided above, writing to us at the above address.

 

You may receive mailings from other reputable companies. You can, however, have your name put on our do-not-share list by calling us at the number provided above, writing to us at the above address.

 

Please provide us with your exact name and address. We will be sure your name is removed from the list we share with other organizations.

 

Persons who supply us with their telephone numbers on-line may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by sending us e-mail at the above address, writing to us at the above address.

 

Persons who supply us with their telephone numbers on-line may receive telephone contact from other reputable companies. You can, however, have your name put on our do-not-share list by, sending us e-mail at the above address, writing to us at the above address.

 

Please provide us with your name and phone number. We will be sure your name is removed from the list we share with other organizations.

 

With respect to Ad Servers: To try and bring you offers that are of interest to you, we have relationships with other companies that we allow to place ads on our Web pages. As a result of your visit to our site, ad server companies may collect information such as your domain type, your IP address and clickstream information. For further information, consult the privacy policies of:

 

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will post the policy changes to our Web site to notify you of these changes and provide you with the ability to opt out of these new uses. If you are concerned about how your information is used, you should check back at our Web site periodically.

 

Customers may prevent their information from being used for purposes other than those for which it was originally collected by calling us at the number provided above.

 

Upon request we provide site visitors with access to no information that we have collected and that we maintain about them.

 

Upon request we offer visitors no ability to have factual inaccuracies corrected in information that we maintain about them.

 

With respect to security: We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our site.

 

If you feel that this site is not following its stated information policy, you may contact us at the above addresses or phone number, The DMA's Committee on Ethical Business Practices at mgoldberger@the-dma.org.

 

U.S. - E.U. Safe Harbor Privacy Policy

 

Clickbooth.com, LLC (“Clickbooth”) recognizes that privacy is very important to our clients and business partners, and we pledge to protect the security and privacy of any personal information that clients and business partners provide to us. This includes clients’ and business partners’ personally identifiable information. Not only does Clickbooth strive to collect, use, and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This US-EU Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Clickbooth follows with respect to transfers of personal information from the European Union (EU) to the United States.

 

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that ensures adequate protection for personal information transferred from the EEA to the United States (the "US-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection. Consistent with our commitment to protect personal privacy, Clickbooth adheres to the principles set forth in the U.S. - EU Safe Harbor.

 

SCOPE

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Clickbooth in the United States from the EU, in any format including electronic, paper or verbal.

 

DEFINITIONS

The following definitions shall apply throughout this Policy:"Agent" means any third party that uses personal information provided to Clickbooth to perform tasks on behalf of and under the instructions of Clickbooth."Clickbooth" means Clickbooth.com, LLC, and each of its predecessors, successors and affiliates."Personal information" means any information or set of information that identifies or could be used by or on behalf of Clickbooth to identify an individual. Personal information does not include information that is encoded, anonymous, aggregated or publicly available information that has not been combined with non-public personal information."Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Clickbooth will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

 

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on and in accordance with the Safe Harbor Principles. Additional information about the Safe Harbor program is available at the U.S. Department of Commerce's website at www.export.gov/safeharbor.

 

NOTICE: When Clickbooth collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Clickbooth discloses that information, and the choices and means, if any, that Clickbooth offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Clickbooth, or as soon as practicable thereafter, and in any event before Clickbooth uses the information for a purpose other than that for which it was originally collected.

 

If Clickbooth receives personal information from other entities in the EU, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.

 

CHOICE: Clickbooth will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.For sensitive personal information, Clickbooth will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.Clickbooth will provide individuals with reasonable methods to exercise their choices.

 

DATA INTEGRITY: Clickbooth will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Clickbooth will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

 

TRANSFERS TO AGENTS: Clickbooth will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). If Clickbooth has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Clickbooth will take reasonable steps to prevent or stop the use or disclosure.

 

ACCESS AND CORRECTION: Upon request, Clickbooth will grant individuals reasonable access to personal information that it holds about them, and Clickbooth will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

 

SECURITY: Clickbooth will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We use reasonable, industry-standard precautions, including appropriate technical, administrative, and physical procedures, to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

 

ENFORCEMENT: Clickbooth uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Safe Harbor Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using an independent resource mechanism as a third party resolution provider.

 

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Clickbooth Privacy Office at the address given below. Clickbooth will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Clickbooth and the complainant, Clickbooth has agreed to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Principles.

 

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the Clickbooth Compliance Department by mail or e-mail as follows:Clickbooth.com, LLC

Compliance and Enforcement

5901 N. Honore Ave.

Suite 210

Sarasota, FL 34243

Email: compliance@clickbooth.com

 

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Clickbooth to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

 

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Clickbooth will provide appropriate public notice on its website whenever this notice is changed in a material way (http://www.clickbooth.com/legal/privacy)

 

EFFECTIVE DATE: September 29, 2014   



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