Privacy Policy
Introduction
At Data Partners, LLC., (“DPI”) your privacy is important to us. We have developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
Scope This Policy applies to the Data Partners web site located at www.datapartners.io, and all associated sites linked to www.datapartners.io by Data Partners, its subsidiaries and affiliates, including Data Partners sites around the world (collectively, the “Site”). This Policy provides an explanation as to what happens to any personal data that you share with us, or that we collect from you either directly via these websites or via email. By using the Sites, you agree to the terms and conditions of this Privacy Policy. This Policy only applies to Personal Data (as defined below) and other information collected by us from: (i) visitors to our Site and users of our Services, (ii) job applicants and (iii) partners and clients.
1. Information We Collect
2. Information Collected Automatically – Cookies
3. How We Use of Your Personal Information and Data
4. Lawful Basis
5. Sharing and Disclosure
6. Storing Your Personal Data and Transfer of Data
7. Third Party Links
8. Individual Rights
8.1 EU
8.2 California
9. Security
10. Sensitive Data
11. Our Policy on Children
12. Contact Us
1. Information We Collect
While using our site, you may provide us with certain personal data that can be used to contact or identify you (“Personal Data”). We may also receive information from clients where we act as a service provider or our partners, which may let us collect information about use of their sites/apps or they may share your information directly with us. There is Personal Data we collect, in accordance with law, that may include, but is not limited to:
· Identification information that can be used to identify you, such as your name, address, phone number, email address, signatures or other identifiers. We may also collect online identifiers, such as your IP address, when you browse our websites or use our applications. We may collect government-issued ID for certain types of interactions like employment – but please provide government-issued ID information only if we ask you to.
· Online activities information, such as browsing history, search history, chat logs, and other information when you interact with our websites, applications, webinars, and advertisements.
· Education information, such as when you apply for a job with us
· Inferences or preferences we learn or infer about you
· Other personal information, if it identifies, relates and can be reasonably associated with or linked to you (or your household)
2. Information Collected Automatically – Cookies
Like many websites, we and our third-party service providers, such as advertising and analytics providers, use cookies, web beacons and other data technologies to receive and store certain types of information when you interact with us through your computer or mobile device. Using these technologies helps us recognize you, customize your experience and make relevant marketing messages. Here are some of the types of information we collect and the types of Cookies we use to do it:
· Strictly Necessary Cookies: These are cookies without which you would not be able to use this Site. For example, Strictly Necessary Cookies adjust the Site data transmitted to match your Internet connection, get you to the secure versions of the Site, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Site will not work. Strictly Necessary Cookies do not store any Personal Information.
· Performance Cookies: We use these cookies to count visits and traffic sources, to measure and improve Site performance. They help us to know which pages are the most and least popular and see how visitors move around the site. Performance Cookies do not store any Personal Information. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Our third-party service providers may provide us information that tells us how our marketing ads, often placed on third party sites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you we would treat it as personal data.
· Functional cookies: These cookies allow the Site to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
· Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the Site and other sites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. To better serve users’ preferences, we have partnered with the Digital Advertising Alliance (http://youradchoices.com), by visiting their website you can learn more about their members who deliver tailored online ads and your choices to opt-out of receiving them. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests. We work with Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
We work with Terminus as a third-party vendor that uses cookies to serve ads on our site. If you would prefer not to have Terminus serve you relevant ads, you may opt out here: Terminus Opt Out.
We specifically use third party services, Google Analytics, Pardot, Adobe Audience Manager, Adobe Target, and Adobe Analytics, to collect standard internet log information, details of visitor behavior patterns, and, in some cases, to more effectively market our products and services through other media platforms and channel. We do this to find out things such as the number of visitors to the various parts of the site. If you would like to opt-out of these 3rd party services, please follow these links:
· Adobe Analytics
· Adobe Audience Manager
· Adobe Target
· Drift
· Google Analytics
· Pardot
· Demandbase
Don’t Want Cookies?
Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example:
· Google Chrome
· Internet Explorer
· Mozilla Firefox
· Safari (Desktop)
· Safari (Mobile)
· Android Browser
· Opera
· Opera Mobile
There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.
Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.
3. How We Use Your Personal Information and Other Data
We will make it clear when we collect personal information and will explain what we intend to do with it. We may use the information we collect about you for various purposes, including:
· To more effectively market our products and services through other media platforms and channels.
· Understand how users interact with the Services, which includes compiling aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future as well as for audience targeting.
· To deliver our marketing emails and newsletters.
· We gather statistics around email opening and clicks using industry standard technologies including transparent gifs to help us monitor and improve our e‑newsletter.
· If you apply for a job with us, we only use the information for the purpose of progressing your application, or to fulfill legal or regulatory requirements, if necessary.
· To provide information about our products and services to you when you fill out the Contact Us form on our Site.
· Provide the Services to you, improve the quality of the service, and develop new products and services;
· Provide you with information about related goods and services which we believe may be of interest to you and fulfill any other business or commercial purposes at your direction or with prior notice to you and your consent;
We use log data for various internal business purposes which include:
· To monitor abuse and prevent illegal activities and fraud,
· To troubleshoot site functionality and fix bugs;
· To track people’s preferences which allows us to create new services, features and content that may be more personalized for you and your interests;
· To track behavior on an aggregated/anonymous level to track and understand trends related to our offerings and services.
4. Lawful Basis of Processing
We may process your data based on one of three main legal grounds: (1) our legitimate interests/provide services; (2) any contract between you and us; and (3) your consent.
· Provide Services: To provide you with information requested from us relating to our products or services and to provide information on other products which we feel may be of interest to you if you have consented to receive such information, which are legitimate business interests. To notify you about any changes to our Website, such as improvements or service/product changes, that may affect our service. If you are an existing customer, we may contact you with information about goods and services similar to those which were the subject of a previous sale to you. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.
· Performance of Contract: We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
· User Consent: If you are a new customer, we will only contact you or allow third parties to contact you only when you have provided consent and only by those means you provided consent for. We may use your data, or permit selected third parties to use your data, so that you can be provided with information about unrelated goods and services which we consider may be of interest to you. We or they may contact you about these goods and services by any of the methods that you consented to at the time your information was collected. If you do not want us to use your data for ourselves or third-parties, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data.
Please be advised that we do not reveal information about identifiable individuals to our advertisers, but we may, on occasion, provide them with aggregate statistical information about our visitors such as your area of residence or age group.
5. Sharing and Disclosure
We do not share your personal information with others except as indicated within this policy or when we inform you and give you an opportunity to opt out of having your personal information shared.
We share your information in the following ways.
· With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services.
· Analytics. Specifically, for analytics providers, we use Google Analytics and Adobe Analytics. These are web analytics service offered by Google and Adobe that track and report website traffic. Each uses the data collected to track and monitor the use of our Service. This data is shared with other Google and Adobe services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Adobe tracks you across all of your devices and creates websites, apps and ads that are customized for you, across your devices without collecting information that directly identifies the individual person.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
You can customize and manage what devices are linked to you by Adobe by visiting this link or control all your data preferences with Adobe by visiting here.
· Advertising. We may use third-party Service Providers to show advertisements, which may include targeted advertisements on a third-party site after you have visited our website. We and the third-party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to our site. Any tracking that a third party performs is subject to their own privacy notice.
Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
We work with Terminus as a third-party vendor, who uses cookies to serve ads on our site. The cookie enables Terminus and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of their cookie for interest-based advertising by visiting this page.
· To comply with legal process or to protect us. If we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to enforce applicable terms of use, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Data Partners, as required by law; or to detect, prevent, or otherwise address, security or technical issues or illegal or suspected illegal activities (including fraud).
· Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party. In the unlikely event that we or substantially all of our assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.
6. Storing Your Personal Data and Transfer of Data
Data Partners administers and operates the Site from its location in Atlanta, GA, USA. If you are located in another juriDPIction, please know that your information will be transferred to, stored, and processed in the United States. By using this site and providing us with information, you consent to this transfer, processing and storage of your information in the United States.
· We may transfer data that we collect from you to locations outside of headquarters for processing and storing. In addition, it may be processed by staff operating outside the office area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this privacy policy.
· Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site will be encrypted to ensure its safety.
· The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.
7. Third Party Links
This Site may contain links to other independent third-party Web sites (“Linked Sites”). These Linked Sites are provided solely as a convenience to our visitors. Such Linked Sites are not under Data Partners’s control, and Data Partners is not responsible for and does not endorse the content of such Linked Sites, including any information or materials contained on such Linked Sites. You will need to make your own independent judgment regarding your interaction with these Linked Sites.
8. Individual Rights
We have operations in the US. Below we will provide information about what your individual rights are depending on where you are located.
8.1. EU Residents
Subject to applicable law, you may have the following rights with respect to the processing of your personal data:
· Choosing not to provide your personal data
· Accessing, or obtaining a copy of, your personal data
· Checking and editing your data in your user account
· Unsubscribing from direct marketing
· Checking and editing your personal data
· Blocking and deleting the cookies
· Permitting or refusing processing of your location data
· Erasure, or restriction of our processing, of your data
· Objecting to the processing of your personal data
· Withdrawing your consent
· Porting your data to another controller
· Lodging a claim at the supervisory authority
We hope to ensure that the personal data we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your personal data, subject to applicable law. We take every reasonable step to ensure that the personal data that we process are limited to the personal data that are reasonably required in connection with the purposes set out in this Privacy Policy.
Please note that upon exercising any of the rights listed below, you may be requested to provide additional information for identification purposes. Such additional information shall not be used for any other purpose and will be removed after successful identification.
· Providing your data: You may choose not to provide your personal data to us. It should be noted that some features of our websites and other services may not be fully available to you if you choose not to provide us with your personal data (e.g., we may not be able to process your orders without the necessary details).
· Right of access: You may have the right to request access to, or copies of, your personal data, together with information regarding the nature, processing and disclosure of those data.
· Unsubscribing: We include an unsubscribe link in all electronic marketing messages we send to you. You may withdraw your consent to direct marketing at any time. If you do so, we will promptly update our databases, and will not send you further direct marketing, but we may continue to contact you to the extent necessary for the purposes of any products or services you have requested.
· Checking and editing your personal data: Should you have an online user account, you may edit and complete your personal data directly yourself. If you do not have an online user account, you may contact [email protected], who will upon your request as soon as possible rectify, remove or complete the information which is incorrect, unnecessary, lacking or outdated.
· Blocking and deleting cookies: You may block the cookies using your browser settings. Please note that blocking the cookies may affect the usability of our websites. You may also delete the cookies from your browser via its settings, in which case the information collected by the previous cookie will not affect the account created based on the information collected after such deletion.
· Advertising: You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings.
· Allowing use of location data: You may give your consent to the use of location data in the options of the device or the application. You may also withdraw such consent at any time from the options menu in your account, or by contacting [email protected].
· Erasure, or restriction of our processing, of your data: Should you believe that we process your data which is not accurate; the processing is illegal; we are not processing your data in accordance with the processing purpose or you want to oppose the processing, you may contact [email protected] to request the erasure, or restrictions on the processing, of your data. Please note that we will investigate your request reasonably promptly, before deciding what action to take.
· Right to object: You may have the right to object, on legitimate grounds, to the processing of your personal data.
· Withdrawing your consent: You may at any time decide to withdraw your consent to the processing of your personal data. If your consent is withdrawn, it does not prevent us from processing your personal data based on other legal bases, such as fulfilling your orders and storing your order data as required by applicable law. However, it should be noted that your account(s) on our web store(s) will be removed, and advantages granted to you via your account will be reset. Please note that withdrawal of consent does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal.
· Right to data portability: You may have the right to have your personal data transferred to another controller, in a structured, commonly used and machine-readable format, to the extent applicable.
· Right to Lodge a Complaint: For European Union residents, if you feel that our processing of your personal data infringes on data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you habitually reside, your place of work or the location of the alleged infringement. If you are located outside of the European Union, you may have rights under privacy laws in the juriDPIction where you live.
8.2. California Residents
Additional Notice for California Consumers – This part of our Privacy Notice applies to consumers who reside in California.
8.2.1. Personal Information We Collect About California Residents
We describe the personal information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled, “Personal Data Collected” above. The information we collect includes the following:
· Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Data Collection section above.
The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above.
· Characteristics of protected classifications under California or federal law list any of these that you collect: Age (40 and older).
· Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.
· Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, advertisements that we display on our websites or mobile apps or on third party sites and apps, or Data Partners pages or accounts on any third-party social media platforms.
Geolocation data.
· Audio information from conference calls or webinars, which may be reported, and electronic information in the form of Internet or other electronic network activity information described above.
· Inferences drawn from (1) the information we collet when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the
· Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
· We collect this personal information from sources that include our clients and other sources referenced in the “Personal Data Collected” section above.
8.2.2. Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes
Data Partners does not sell your data —we are not data brokers, and we don’t put your data on the open market. However, under the CCPA, some sharing of personal information necessary to provide you with personalized ads and with some of our partners may be considered a “sale,” even if no money is exchanged. In that respect, we have disclosed email addresses and contact information to other businesses and third parties which include our joint marketing partners when we host webinars and events with them within the twelve (12) months preceding the effective date of this Privacy Notice. As is common practice among businesses that operate websites, we may also have disclosed certain online identifiers, information about the use of our website and inferences drawn about you to our social media, advertising and analytics partners.
We have disclosed personal information in all or substantially all of the categories identified in this Additional Notice for California Resident Consumers for various business purposes. For more information about the categories of personal information we have disclosed, the categories of entities with which we have disclosed this information and the purposes for which we have disclosed the information, please see “Use of Your Information” above and “Where and How We Share and Disclose Your Information”.
For information regarding the purposes for which we collect and use the personal information we collect, please see “Use of Your Information” and “Where and How We Share and Disclose Your Information” sections above.
8.2.3. Your California Privacy Rights
If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
8.2.3.1. Right to Access and Information Regarding Personal Information
You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
· The categories of personal information we have collected about you;
· The categories of sources from which the personal information is collected;
· Our business or commercial purpose for collecting or selling personal information;
· The categories of third parties with whom we share personal information;
· The specific pieces of information we have collected about you;
· The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
· The categories of personal information about you that we disclosed for a business purpose.
We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you through your account, if you maintain an account with us, or electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance.
8.2.3.2. Right to Deletion of Personal Information
You have the right to request that we delete Personal Information about you that we have collected from you.
8.2.3.3. Right to Opt Out
We may not discriminate against you because of your exercise of any of the foregoing rights under the California Consumer Privacy Act, including by:
· Denying you goods or services;
· Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
· Providing you a different level or quality of goods or services; or
· Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.
We may however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.
8.2.3.4. Right to No Discrimination
You have the right to opt out of the disclosure of personal information about you for monetary or other valuable consideration. To Opt-Out, visit www.datapartners.io/contact.
8.2.4. Requests to Exercise Your Rights
You may request to exercise the foregoing rights by:
· Submitting a request to www.datapartners.io/contact
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.
8.2.5. Data Sharing for Direct Marketing Purposes
California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at [email protected] or by writing us at the address below.
9. Security
We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information.
10. Sensitive Data
We request that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send us this information, then you are consenting to its processing in accordance with this privacy notice. To avoid processing of sensitive data, do not submit it.
11. Our Policy on Children’s Information
Our site is not directed to children under 18. If you learn that your minor child has provided us with personal information without your consent, please contact us.
12. Contacting Us
This privacy notice does not provide exhaustive detail of all aspects of DPI’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to: [email protected]
If you would prefer to write to us then our contact address is:
In the US:
135 Madison Ave
New York, NY 10016