DigiCenter Privacy Policy

DigiCenter, LLC.
PRIVACY POLICY

Last modified: July 2020

This Privacy Notice applies to information DigiCenter, LLC (“DigiCenter” or “we”) may collect from visitors to www.digicenter.com (the “Site”) and through services we provide on behalf of and for various clients, as described below (the “Services”). The purpose of this website privacy notice is to explain how we collect, use, and share such information.

Please note that this Privacy Notice does not apply to the collection, use, manipulation, storage, destruction, disclosure, and/or processing of any information by third parties, which information is subject to the privacy notice of that particular third party.

DigiCenter Services

DigiCenter provides data connectivity and marketing services designed to enable our clients and their customers to reach consumers with greater efficiency and more relevant messages across various digital channels, including online and mobile.

Information We Collect Through the Site

You may chose to contact us by email using the contact us feature, in which case we will collect your name, email address, phone number, and any other information that you chose to provide to us. Please do not provide information that you do not want us to have.

In addition, we may gather information about you automatically through your use of the Site, e.g., your IP address and how you navigate our Site (“Automatically Collected Information”). We may collect Automatically Collected Information about you by using cookies, tracking pixels and other technologies (collectively, “Tools”). We may use this information to better understand, customize and improve the user experience of our websites, services and offerings. For example, we may use web analytics services such as Google Analytics that leverage Tools to help us understand how visitors engage with and navigate our Site. Information on how Google Analytics collects and processes your data is available here: www.google.com/policies/privacy/partners.

How We Collect Information Automatically Through the Services

We and/or our Partners use cookies and standard web technologies to collect Usage Data automatically, including the following:

Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit a website. Both cookies and local storage can be used to store device identifiers whenever you visit one of our client’s websites. Most browsers provide you with the ability to disable or decline cookies and local storage.

Web Beacons. Web Beacons are small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) that are included in our clients’ websites or emails.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a website. The code is temporarily downloaded onto your device from our web server, is active only while you are connected to the website, and is deactivated or deleted thereafter.

SDKs and APIs. SDKS and APIs are programming codes that collect information about your interactions with mobile apps and websites. This code is installed on a device, typically within our clients’ applications that you choose to download onto your mobile device.

How We Use the Information We Collect Through the Site

If you choose to provide information to us, for example, by contacting us, the information is used for the purpose you provided it to us. For example, if you provide your contact information in an inquiry to us, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry.

We may use Automatically Collected Information to better understand how our visitors use the Site, analyze their demographics, interests, and behavior, to improve the content of the Site and further develop our businesses and services.

How We Use the Information We Collect Through the Services

We use information collected through the Services:

To provide the Services to our clients. Generally, we use the information we collect about you to help our clients and their customers to better understand their consumers and potential consumers and better target and customize marketing, websites and content, and measure and optimize the performance of their marketing.

To build various inferenced data segments (“Data Segments”). We may use the information we collect to help our clients build Data Segments related to, for instance, the industry you are in or the type of content in which you appear to be interested. We use these Data Segments to help our clients or their customers, understand their own consumers. The Data Segments also may be associated with matchkeys, cookies, mobile device advertising IDs or other identifiers.

To do “interest-based advertising”. We work with clients and Partners to help them target ads to you that are based on your offline interests, transactions or demographic information. This is often known as “interest-based advertising.” You can find out more about this type of advertising at the DAA’s website, located at http://www.aboutads.info.

To do cross-device tracking. We (or Partners and clients we work with) may use the Usage Data – for example, IP addresses, hashed email addresses, and UIDs – to try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with providers that do this, in order to enable our clients to better target ad campaigns to common sets of users. For instance, a brand may wish to target consumers that it usually recognizes on web browsers through mobile apps.

To do “user matching”. We (or our Partners) may also use your information to sync cookies and other identifiers with other Partner and clients (“user matching”). For example, a user may have been assigned in our system, we may also receive a list of matchkeys that our Partners or clients have assigned to a user.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How We Share the Information We Collect for Business, Commercial and Third Party Purposes

We may share information about you with our affiliates for the purposes described in this Notice.

We may share information we collect through the Services with our clients and Partners who may use the information in ways consistent with the uses described in this notice. Partners may include Third Parties who leverage and use the data for the following use cases: Third Party Marketing, Third Party Analytics, Third Party Measurement, Third Party Advertising, Third Party Segments, and Third Party Product Creations. The purpose of sharing data with Partners and Third Parties is for the following purposes: Product enhancement that benefits DigiCenter and its clients, commercial purposes, advertising purposes, product development purposes, marketing purposes, and analytics/insights purposes.

We may share information with service providers that perform services on our behalf such as analytics providers and hosting providers. In addition, we may disclose information (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in conjunction with (i) the making, management, or disposition of any of our investments, or (ii) business continuity.

Opting out of interest based advertising from cookies

There are several ways you may opt-out of our automatic data collection through our Services:

Opt-Out Cookie and Mobile: Opt out by accepting a cookie or mobile device, which tells DigiCenter not to uniquely track your web browsing or mobile device. Click https://www.digicenter.com/opt-out/ to opt out now. If you change computers, browsers, devices or use multiple computers, browsers, devices or delete your cookies, you will need to repeat this process for each computer, each browser and each device. If your browser is not configured to accept third-party cookies, then your opt-out preference cannot be stored.

Industry Opt-Outs. We support the self-regulatory principles of the Network Advertising Initiative (“NAI”). You may use the NAI opt out tool (found here: http://optout.networkadvertising.org/?c=1), which will allow you to opt out of seeing targeted ads through your web browser from NAI member companies. We also support the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (“DAA”). You can visit the DAA opt-out page here: https://www.aboutads.info/choices/.

Mobile App Opt Out. For mobile apps, you can typically limit ad tracking using the settings on your phone, tablet or other mobile device using the “Ads” menu, “Ad Tracking” setting, or similar setting on your device. Mobile device operating systems such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads based on their interests. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices and “Limit Ad Tracking” on iOS devices). Please also see the NAI’s mobile opt-out instructions.

Location. Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device.

Please be aware that opting out does not mean that you will no longer receive targeted marketing messages in your mobile apps or web browsers. You may still receive generic advertisements and you may see targeted advertisements based on information collected and used by entities other than us.

Do Not Sell My Personal Information

As described, in performing our Services, we may make available to our clients identifiers, such as online identifiers and IP addresses, as well as internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.  Under the California Consumer Privacy Act (CCPA), this activity may be considered “selling” data. To opt-out of these “sales” of data, please use our opt-out link, available here.  We will honor you opt-out request, and transmit that request to any Client with whom we have disclosed your information.

Data Retention

For information collected through the Services, we retain it for the period allowable under our contractual agreements or until we receive a request to delete it.

Links to Third-Party Websites

The Site may contain links to other web sites. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another web site, you may be asked to provide registration or other information. Please note that any information that you provide is going to a third party, and therefore you should familiarize yourself with that party’s privacy Notice.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. We do not change our practices, described elsewhere in this privacy notice, in response to DNT browser settings or signals. For information about DNT, visit www.allaboutdnt.org.

Third parties may collect personal information about your online activities over time and across different websites, including your use of this Site. This Privacy Notice does not apply to, and we are not responsible for, the practices of third parties that collect your personal information.

Children

We are committed to protecting the online privacy of children. In accordance with the Children’s Online Privacy Protection Act, we will not knowingly collect any personally identifiable information from or provide any services to children under the age of 13. Unfortunately, we cannot always determine the age of a visitor to our site or the sender of an email. If for some reason we learn that a user is under 13 years of age and we can identify personal information relating to such a user, we will take steps to delete such information promptly.

Your Rights Under the California Consumer Privacy Act (CCPA)

Depending on your residency, you may have certain data subject rights. These rights vary by state and country, but for California residents they include the right to: (i) request additional disclosures about the Personal Information we collect, use, and disclose, i.e., a “Request to Know (Categories of Information)”; (ii) obtain a copy of Personal Information, i.e., a “Request to Know (Specific Pieces of Information),” sometimes called the Right to Access; (iii) request deletion of Personal Information, i.e., a “Request to Delete Information,” sometimes called the Right to Be Forgotten; and (iv) opt out of the sale of Personal Information, i.e., a “Request to Opt Out.” We will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services. However, we may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.

How to Exercise Data Subject Rights

If you wish to exercise any of these rights please email privacy@digicenter.com with the phrase “California Data Subject Rights” in the subject line. You may also call us toll-free at 1-617-655-8550 or complete this web form https://www.digicenter.com/opt-out/.  To submit a Request to Opt-Out, please click https://www.digicenter.com/opt-out/, and we will automatically honor your request.  For all other requests, we will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

Additional California Privacy Rights

California residents may request and obtain once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. California residents may also choose to opt out of such disclosures, if any. 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 we shared information in the immediately preceding calendar year. California residents may make such a request in writing by emailing privacy@digicenter.com with your name and address, and noting “California Shine the Light Request” in the subject line of the email.

Additional CCPA Disclosures

Under the CCPA, we are required to provide you with specific disclosures about the categories of personal information we collect, categories of sources from whom we collect such information, our commercial purpose for collecting and selling such information, and the categories of third-parties with whom we share such information.  We have already described our collecting and use of your information throughout this policy, but provide that information here in a summary table:

Categories of Information

Sources

Commercial Purposes

How We Share

Identifiers.

-From you;

-Automatically when you use our Site;

-From our Partners;

-From our Clients.

-To respond to your inquiries;

-To better understand how our visitors use the Site;

-To analyze user demographics, interests, and behavior;

-To improve the content of the Site and further develop our businesses and services;

-To provide Services to our clients

-To build Data Segments;

-To do “interest-based advertising”;

-To do cross-devise tracking;

-To do “user matching”;

-For other purposes described above.

-With our vendors and service providers;

-With our Clients.

Internet or other electronic network activity information.

-Automatically when you use our Site;

-From our Partners;

-From our Clients.

-To better understand how our visitors use the Site;

-To analyze user demographics, interests, and behavior;

-To improve the content of the Site and further develop our businesses and services;

-To provide Services to our clients

-To build Data Segments;

-To do “interest-based advertising”;

-To do cross-devise tracking;

-To do “user matching”;

-For other purposes described above.

-With our vendors and service providers;

-With our Clients.

Geolocation information.

-Automatically when you use our Site;

-From our Partners;

-From our Clients.

-To better understand how our visitors use the Site;

-To analyze user demographics, interests, and behavior;

-To improve the content of the Site and further develop our businesses and services;

-To provide Services to our clients

-To build Data Segments;

-To do “interest-based advertising”;

-To do cross-devise tracking;

-To do “user matching”;

-For other purposes described above.

-With our vendors and service providers;

-With our Clients.

Other information you may provide us.

-From You.

-To respond to your inquiries

-With our vendors and service providers.

How to Contact Us About Privacy Matters

If you would like to contact us for any reason concerning our privacy practices, please email us at privacy@digicenter.com.

Updates to This Privacy Notice

We may change or update portions of this Privacy Notice at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Notice. The revision date appearing on the first page of this Privacy Notice underneath the title will identify the date of the last update or revision.