Effective Date: April 22, 2019
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We collect different categories of personal information about you from different sources, including information you provide us directly, usage information about your visits to our Sites and information provided by third parties.
We collect information you provide to us directly when you use our Sites. This includes:
When you use or access our Sites, we may also automatically collect information about you. This includes:
We generally use the information we collect about you to operate, manage and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including:
We, our service providers and third-party advertising partners use technologies that automatically collect information about Site visitors and their visits to the Sites, including as described below.
We automatically collect information about how you access, navigate and leave our Site, including the website you came from before visiting our Site, what browser type and operating system you are using, the internet protocol (IP) address you are accessing the Site from, your mobile device ID or Advertising ID if you visit our Site from a mobile device, the pages of our Site that you are navigating through, the date and time of your visit, how long you spend on our Site or certain pages of our Site, and what website you go to after visiting our Site. This information may be used to determine how many visitors visit our Site or certain areas of our Site, how long they remain on our Site, whether they use the hyperlinks we provide or respond to advertising and to tailor our advertisements to you. We may share this information with partners who referred you to our Site, and with advertising partners, who may use the information to optimize the traffic they send to us and for delivering targeted ads to you when you visit other websites.
We, our service providers and third-party advertising partners collect information about Site visitors using cookies and other tracking technologies (including browser cookies, pixels and Adobe Flash). We use these technologies to remember your preferences and facilitate your navigation of our Site. We and our service providers and third-party advertising partners also use these technologies to track your activities on our Site and other websites, including the websites and web pages that you visited, the ads or content that you clicked on, any items you may have purchased and the search terms you used, in order to deliver tailored advertising to you. We may also share a unique identifier linked to you (such as a hashed or encrypted version of your email address or telephone number) with advertising partners so that you may be served with tailored advertising on our websites or other third party websites. However, you may opt out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you by visiting Digital Advertising Alliance of Canada Opt-Out Page, Your Online Choices from the European Interactive Digital Advertising Alliance, NAI Opt-Out Page and the Ad Choices Opt-Out Page.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. See Your Choices below for information about your choices about how we use and share your information.
We use Google Analytics to help us understand how our Site visitors use the Site, and as well as certain features of Google Analytics Display Advertising to advertise online, sell advertising and to develop content. You can opt out of your usage data being included in our reports from Google Analytics and customize Google’s Display Network ads. Please visit Google’s Ad Settings and Google Analytics Opt-out Browser Add-on. Please visit How Google uses data when you use our partners' sites or apps for a description of how Google uses information sent by our browser and for ways you can control the information sent to Google.
Most modern web browsers provide the option to send a “do not track” signal to the websites you visit, indicating that you do not wish to be tracked. At this time, there is no generally accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Our third party partners, such as web analytics companies and third party ad networks, collect information about your online activities over time and across the Sites and other online properties. These third parties may not change their tracking practices in response to “do not track” settings in your web browser and we do not obligate these parties to honor “do not track” settings.
We may share information we collect about you in the following circumstances.
We share information with our third-party advertising partners as described in the Cookies, tracking technologies and interest-based advertising section above.
We may use service providers (including affiliates acting in this capacity) to provide services to us or to you on our behalf. For example, our service providers may host our Site, analyze data collected from our Site, provide customer service on our behalf, administer our promotions, facilitate and process transactions and payments, provide marketing or promotional assistance, distribute emails and other communications, post our advertisements (including online through targeted advertising campaigns), and collect your feedback on our Site and advertisements. We share your personal information with our service providers solely for the purposes of providing services to you and to us. They are not permitted to use your personal information for other purposes. Some of our service providers are located outside of Canada, including in the United States. While your personal information is located outside of Canada, it will be subject to legal requirements applicable to our service providers, for example, lawful requirements to disclose personal information to national security agencies or government authorities in certain circumstances. For EU residents, see Users from the European Union section below.
We may use your personal information to create aggregate statistics and de-identified data. We may use, share and sell this information for any purpose.
We may disclose your personal information to third parties in connection with the proposed or actual financing, securitization, insuring, merger, sale, assignment or other disposal of all or part of VerticalScope or our business or assets. These third parties may use the information for the purposes of evaluating and/or completing the proposed transaction and thereafter as a successor of our interests.
We may disclose your personal information in other circumstances where permitted or required by law or other legal process. For example, we may disclose your personal information: (a) to collect a debt owed to us; (b) as necessary to comply with a subpoena, warrant, court order or other legal process; (c) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation or other legal process; or (d) if we have reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law, or to protect the personal safety of our users or defend our rights or property.
The security of your information is important to us. While we have implemented safeguards to protect the information we collect, no website or internet transmission is completely secure, and we cannot and do not guarantee the security of your personal information. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when you have finished using a Site on a shared or unsecured device.
We maintain personal information on our servers (or those of our service providers). Certain accounts you create on our Sites are password protected. If you create an account on the Site, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security. In identified parts of our Sites, we use SSL-encryption in an effort to protect data transmissions. Our policy is to limit access to sensitive personal information to employees, representatives and service providers who require access in connection with their job or service responsibilities.
Our Sites are not directed to and we do not knowingly request or collect personal information from children - persons under 13 years of age, or another age if required by applicable law - without prior verifiable parental consent. If we become aware that we have unknowingly collected personal information about a child without verifiable parental consent, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.
We encourage you to keep your personal information accurate and up to date. If you have an account with us, you can access and correct certain of the information in your account or public user profile by logging in to your account or profile and making the necessary edits.
You may request access to or correction of your personal information in our custody or control by contacting us as set out below. We may take reasonable steps to authenticate your identity before providing you with access to your personal information or making corrections. Please also note that in some cases we may not be able to provide you with the personal information you have requested (for example, if the information is subject to solicitor-client privilege or contains personal information of others that cannot be severed).
VerticalScope is the data controller for processing of information defined as personal data under the General Data Protection Regulation (“Personal Data”). VerticalScope participates in the IAB Europe Transparency & Consent Framework (“TCF”) and complies with its Specifications and Policies. VerticalScope uses the Consent Management Platform with the identification number CMP ID 10.
Your personal information will be retained for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our Site and receipt of our services.
Legal Basis for Data Processing
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.
International Transfers of Personal Data
Our personnel and some of the third-parties to whom we disclose Personal Data (as set out above) may be located in countries outside of the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and, where required under law, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data remains protected and secure. A copy of these clauses can be obtained by emailing [email protected]
You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting us by emailing [email protected]
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, if you consider that our processing of your Personal Data infringes applicable law.
We have collected the following categories of personal information in the preceding 12 months:
We collect personal information directly from you, indirectly from you (i.e., from observing your actions on the Sites) and from other sources (i.e., information from social media platforms, advertising networks, internet service providers, analytics providers, operating systems and platforms, data brokers, commercially available sources, our affiliates or other business partners).
In the preceding 12 months, we have shared the categories of personal information listed above for business purposes with our service providers, business partners and affiliates who assist in providing our services or operating our business. Examples of these third parties include social media platforms, advertising networks, internet service providers, analytics providers, operating systems and platforms, content providers and other business partners.
The CCPA broadly defines “sale” in a way that may include allowing third parties to receive certain data, such as cookie information, IP address or browsing behavior, to deliver targeted advertising on our Services or other sites and apps.
Based on this, in the preceding 12 months, we have “sold” and, subject to your opt-out right described below, may in the future “sell” the following categories of personal information to third parties, including third party advertising networks, social media platforms and other business partners for advertising purposes. Advertising, including targeted advertising, enables us to provide you with certain content for free and to provide you with content and ads that are relevant to you.
We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
Subject to certain exceptions under the CCPA, you have the right to request that we disclose the following information to you:
You have the right to request that we delete the personal information we collected about you, subject to certain exceptions provided by the CCPA. Once we receive and confirm your verifiable request, we will delete the requested personal information from our records, unless an exception provided by the CCPA applies.
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected]
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. You will need access to the email account associated with your user account in order to allow us to verify your identity and complete this process. Please describe your request with sufficient detail for us to properly understand, evaluate and respond to it.
Subject to certain exceptions under the CCPA, you have the right to opt out of the future “sale” of your personal information. To do so, you may submit a request by clicking on the “Do Not Sell My Data” link displayed on the homepage or webpage of the Site visited. Your browser must be set to accept cookies. If you access the Site from other devices or browsers, you must submit a request from each device and browser separately. If you delete your cookie history on a particular browser or device, the opt-out will no longer be effective and you will have to submit a new request on that browser or device.
If you opt out of the future “sale” of your personal information by clicking on the “Do Not Sell My Data” link, that does not mean you will stop seeing ads, but they may not be as relevant or useful to you.
If you would like to designate an agent to submit a CCPA request on your behalf, the agent must be registered with the California Secretary of State to conduct business in California. Please send us an email at [email protected] for instructions and details on proof required for use of an authorized agent, including a copy of the written legal authorization signed by the consumer for the agent to act on the consumer’s behalf in this manner.
You have the right not to receive discriminatory treatment by us for exercising any of your CCPA rights.
You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions included in each communication and/or by selecting your communication preferences in your account or profile, if applicable. Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your account, activities, transactions and communications with us.
You may be able to control the information we received from your device or from third parties (such as social media networks) by changing your device settings, browser settings or privacy settings.
You may withdraw your consent to our collection, use or disclosure of your personal information, subject to contractual or legal restrictions and reasonable notice. However, if you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to provide you with certain products or services.