Depending on the circumstances, we may use different legal bases to process Personal Information. For example, in some jurisdictions, when a user explicitly consents, then we may have the right to place cookies on the user’s machine. In other circumstances, we process Personal Information when required to do so by law, or if necessary to protect your interests or the interests of a third party. We may also process data based on our legitimate interests (including, under appropriate circumstances, to provide services to our customers, to operate our business, to conduct direct marketing, and/or to maintain security), provided that such interests are not overridden by the fundamental rights and freedoms of individuals.
PERSONAL INFORMATION WE COLLECT; COLLECTION METHODS
The categories of Personal Information we may collect about you could include the following:
- Identifiers: Information that identifies you directly or could be used to identify you (for example, name, email address, social media account information, phone number, job title and description, company name, customer account information, IP address, and other data that identifies or could identify your online activity).
- Commercial Information: Information related to purchases that you or your company might make in connection with our services (for example, purchase history or products considered). If you are a user of our Service, commercial information we receive may also include sales pipeline and financial data of our users submitted by you in connection with your use of the Service.
- Online Activity: Limited information about your use of the internet collected via web analytics (for example, browsing and/or search history regarding sites visited before or after visiting our websites, the type of operating system used to connect to our websites, interactions with our services or advertisements, browser type, Internet service provider, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and your preferences when you use the websites).
- Geo-IP Information: Information about where your computer or device is approximately located (at the city or state level) when you use the websites.
- Inferences: Information we can determine or estimate about you based on information we collect about you (for example, purchase preferences, potential future purchase behavior).
- User-Generated Content: Information users post on our Service, such as comments or reviews.
- Other Information You Provide: Any other information you provide to us (for example, information you provide to us in any communications with us relating to the Service).
Depending on your relationship and method of interaction with C99, we may collect Personal Information from you in different ways. We may receive certain Personal Information as a result of different categories of interactions with us, including (1) from individuals who interact with any Customer Site that uses a C99 Tag and/or Offsite Content (as defined below) that includes a C99 Pixel/Web Beacon, (2) from users of our Service who submit information through our online platform, mobile applications, or otherwise to the Service, and/or (3) from non-user individuals who otherwise interact without website or applications. Some of the ways that we may collect Personal Information include:
- Information You Provide: When you give us Personal Information directly, including information you submit through our Service as a user (for example, in connection with registering an account with us), or by emailing or calling us in connection with products, services, or other information. This Personal Information includes any specific identifiers you provide directly to us, as well as any commercial information containing Personal Information that you provide to us in connection with the Service (for example, financial budget or sales pipeline information that you submit or make available to the Service in order to receive our products or services, such as when users submit budgeting data to our Service to facilitate their receipt of certain services – we use such user-submitted data solely for purposes of providing the Service to the applicable user as further described in Section 9).
- Activity on our Site/Service: Information about your online activity automatically collected through our site and mobile applications when you interact with them, such as your Internet protocol (IP) address, cookie identifiers and other identifiers that are automatically assigned to your computer or devices when you access the Internet.
- Activity Data: When our users use our Service, we receive information from aspects of the Service, including information about third-party visits to websites our users operate or control (“Customer Sites”) gathered through the use of C99 Tags (defined below in Section 9), including information pertaining to referring sources, pages viewed, IP address, and related information. We also receive certain tracking information generated by C99 Pixels/Web Beacons (defined below in Section 9) related to third-party interactions with Offsite Content (defined below in Section 9), including information pertaining to viewability of, and response rates to, the applicable Offsite Content. Some of the data received as described in this paragraph in connection with the use of C99 Tags may be considered Personal Information in certain contexts, such as Internet protocol (IP) address, cookie identifiers and other identifiers that are automatically assigned to your computer or devices when you access the Internet. The information collected through use of our Pixels/Web Beacons does not include, and is not intentionally combined with, Personal Information.
- User Information: We receive information submitted by users of our Service through our online platform, mobile applications, or otherwise to the Service, including information related to customer budgeting/spend data submitted in order to facilitate their receipt of certain aspects of the Service (“User Information”).
- Third-Party Providers/Licensors: We license or otherwise obtain data, including Personal Information, from third parties who license, sell or provide the data they have collected, including publicly available information about businesses and their activities. From these third parties we obtain categories of Personal Information related to where and how individuals and companies do business and use the internet. We may also acquire Personal Information from third parties who license, sell or provide data they have collected for use in connection with our internal marketing purposes as described in Section 3, below. We may also generate or receive predictive data or inferences about business users such as account characteristics, interests or business buying behavior, including by combining sources of data described above.
HOW WE USE PERSONAL INFORMATION
Business/Commercial Uses of Personal Information: We use the Personal Information we collect for the following business and/or commercial purposes:
- To Provide and Improve our Products and Services: We use Personal Information to operate, improve and personalize our business and services. This use includes collecting data through integrations with email or other systems, deriving insights, trends, use, and analytics, whether actual or predicted, from Personal Information collected, as well as troubleshooting or improving our services. Our Service uses Activity Data collected from our use of C99 Tags and C99 Pixels/Beacons (as described further in Section 9, below), combined with information we receive from third-party providers and licensors as described above and User Information, to provide aspects of our services including to (1) provide the user operating the Customer Site with information on site visits, interactions with Offsite Content, and related information, and (2) generate averages, rankings, and related benchmarking analysis for various marketing channels and vendors associated with those channels to provide and improve our services. We may work with third parties to receive data or insights related to our services and combine that information with the data and insights provided by our Service. We do not make available to third parties the domain names of your Subject Site, or individualized user data associated with the Activity Data we receive.
- Administrative Purposes: We use Personal Information for billing, account management, invoicing, customer service, investigating security and privacy incidents, as well as other legitimate business interests.
- Research and Development: We may perform survey research (online and offline). Sometimes we may ask third parties to conduct this research for us. You do not have to participate in these surveys. We will use the information we collect for research and reporting purposes to help us improve our Service. Similarly, if you post any user-generated content to our Service, we may use this information to improve our products or overall customer experience.
- As required by applicable law, legal process or regulation. We may use all Personal Information we collect or receive as required under law, legal or financial processes like audits.
- To provide reporting. We may use Personal Information to create reports (such as performance analytics, statistics, metrics and other details) for our customers on the companies that visit their websites as well as actual or predicted interests for those visitors. We may also use Personal Information to carry out actions requested by our customers, such as combining data with additional data in our possession or provided by customers or using data to retarget specific companies’ users with personalized advertising.
De-Identified and Aggregated Information: We use Personal Information and other information you provide to us or that we collect about you and others to create de-identified and aggregated information that does not directly identify any individual or household. We use this information for a variety of functions, including providing services to our users, learning more about our current services, and developing new services. De-identified or aggregated information is not Personal Information. We may share this information within with third parties, including but not limited to our users, in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
Other Uses: We may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Combining Personal Information: As described above, we may acquire information from third parties to combine with Personal Information we have already collected from other sources. We may acquire this information for our internal marketing purposes, and also to provide to our users as part of our services.
HOW WE SHARE PERSONAL INFORMATION
- Service Providers. We may share your Personal Information with third-party contractors, partners, vendors and providers we use to perform functions on our behalf or on behalf of our users for business purposes, including hosting or enriching data. These providers will have access to your Personal Information under agreements limiting their use of such Personal Information as necessary to perform business purposes arising their functions as service providers, and may not use it for other purposes.
- Business Partners. C99 may share Personal Information with our business partners or affiliated entities to fulfill our contractual commitments, or to provide you with a product or service that you have requested. We also share this information for marketing or sales purposes including in connection with conferences or events where (if applicable) you have consented to sharing. C99 may also provide Personal Information to business partners we work with to jointly offer products or services, or whose products or services we believe may be of interest to you.
- Users. We may share publicly available information that we collect and process for our users, as well as information we infer based on such information and our analysis of Activity Data, with our users. Our users’ privacy policies discuss how they will use this information to the extent it includes Personal Information.
- Affiliates. We may share Personal Information with entities that own, are owned by, or under common control with, C99.
- Disclosures for Legal or Similar Purposes. We may disclose your Personal Information if necessary to: (i) comply with a court order, subpoena or other legal obligation; (ii) to enforce our policies or contracts or other commitments; (iii) when we reasonably believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution; or (iv) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- Other Sharing with Your Consent. We may share your Personal Information for any other purpose if we have your consent to do so. If you consented to a specific use of your Personal Information but wish to revoke your consent for future use for that purpose, you may contact us as provided in the Contact section below.
HOW WE PROTECT PERSONAL INFORMATION
We employ reasonable and appropriate administrative, technical and physical safeguards appropriate for our size and resources and the types of information that we process to protect and secure data, including Personal Information, in our possession, and to prevent its loss, misuse and unauthorized access, disclosure, alteration, or destruction. Still, transmitting information via the internet is not always secure. Although we do our best to protect information, we cannot guarantee the security of your Personal Information. We do not accept liability for unintentional disclosure and you acknowledge that we are not responsible for any intercepted information sent via the internet. Our Security Policy (https://channel99.s3.amazonaws.com/policy/c99-infosecv1.pdf) provides additional details about how we protect data.
We maintain Personal Information for as long as necessary as appropriate to provide our products and services, comply with our legal obligations, resolve disputes, enforce our agreements, and administer our business.
If you suspect a vulnerability impacting the C99 Service, please share the applicable details by contacting us at email@example.com. We ask that you provide as much detail as possible so that we can verify and reproduce your results to address the potential issue. Please do not publish or share any details of the suspected vulnerability with third parties or online except with our permission once it is resolved.
By using our Service or otherwise providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice or sending an e-mail to you. You may have a legal right to receive this notice in writing.
You have the right to request that we correct or otherwise amend your Personal Information in our possession. If you use our Service, you may be able to correct your own Personal Information through your account. If we have received your Personal Information from one of our customers, or if we have otherwise received Personal Information about you in our capacity as a data processor and/or service provider for another business, we may ask that you work with the customer to amend your Personal Information. We may also ask for appropriate proof of the accuracy of your amended Personal Information before we make a requested change.
If we send direct marketing emails to you, we will include an “unsubscribe” link at the bottom of such emails to allow you to object to our use of your Personal Information for direct marketing. If you click the link to unsubscribe, we will remove you from future direct marketing emails within a reasonable amount of time. You will continue to receive transaction-related emails regarding products or services you have requested. We may also send you other non-promotional emails that you will not be able to opt out of (e.g., communications regarding updates to our Terms of Service or this Policy).
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that our websites and applications are not designed to respond to DNT requests from browsers.
EU DATA SUBJECTS
For residents of the European Economic Area, Switzerland and/or the UK, you may have the right to request to access or delete your Personal Information that we process. Under certain circumstances, you have the right to receive Personal Information that we process about you and transmit that information to another organization, i.e., a right to data portability. Where we previously obtained your consent in order to process your Personal Information, you have the right to withdraw that consent. You may also request that we restrict or block future processing of your Personal Information.
If you would like to exercise any of your foregoing rights, please contact us or send a written request to the address shown under below. We will validate these requests and carry out valid requests. If the request is not deemed valid, then we will share the reasons why it is not valid and your options for seeking resolution through a supervisory authority and through judicial remedy.
You may also have the right to lodge a complaint against us. To do so, you should contact the data protection authority in the country where you are located.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (“CCPA”) provides certain legal rights for California residents. This section generally describes those rights and how you may exercise them in connection with our practices described in this policy.
If you are a California resident, you may exercise these rights or designate an authorized agent to exercise these rights on your behalf.
Once per calendar year, you may request that a covered business disclose to you what “Personal Information” as defined in the CCPA it collects, uses, discloses and sells, and the specific Personal Information such business have collected about you in the prior 12 months.
You have the right to request to know more details about the categories or specific pieces of Personal Information a covered business collects (including how used and disclosed), to delete your Personal Information, to opt out of any “sales” (as defined in the CCPA) that may be occurring, and to not be discriminated against for exercising these rights.
COOKIES, PIXEL TAGS/WEB BEACONS AND ANALYTICS INFORMATION
As discussed above, our Service uses C99 Tags (defined below) and C99 Pixels/Web Beacons (defined below) to gather Activity Data from third-party visitor interactions with Customer Sites and Offsite Content. The functionality of these C99 Tags and C99 Pixels/Web Beacons and your interaction with them depends on the privacy practices and policies of the operators of the Customer Sites and senders of the Offsite Content.
As referenced in the applicable sections above, we use C99 Tags to collect Activity Data related to visits to Customer Sites and C99 Pixels/Web Beacons to collect Activity Data relating to Offsite Content, and we combine Activity Data with User Information and to create benchmarking data and related analysis made available to the applicable users as part of our Service, as well as to develop and improve out products and services.
Some browsers have incorporated “Do Not Track” (DNT) features. Our Service does not respond to DNT signals.
OTHER RIGHTS AND IMPORTANT INFORMATION