iPromote Web User Privacy Policy

Last Update: 06/25/2020

This privacy policy discloses the privacy practices of iPromote.

2KDirect, Inc., a Delaware corporation, doing business as iPromote, ("we", "us" or "iPromote") are very concerned about end users' ("Users", "End Users", "Web User" or "Web Surfers") privacy. To this end, we provide you with this Web User Privacy Policy ("Privacy Policy") to explain to you about our data collection and protection practices when you access, use, interact or engage with our website and/or services.

Please note that this Privacy Policy is an integral part of our Terms of Use (available at: https://bravenet.ipromote.com/terms/). If you do not agree to this Privacy Policy and to the data collection practices we describe here, please do not use or in any other way engage with our services. Please make sure you read the Privacy Policy carefully, understand it and consent to its terms.

iPromote and The Collection of Personal Information

The term "Personal Information" means information that may be used, either alone or in combination with other information, to personally identify a natural person, (e.g., first and last names, email address, phone number and contact information). In some jurisdictions, Personal Information may also include your IP address.

A. Type of Data: IP and Technical Non-Personal Data

When a Web Surfer engages with our ads, iPromote, itself or through its partners, or third parties that we have contractually engaged with, collect certain types of data that enable iPromote to provide its services:

  • Browser information: type, settings, language and cookie information;
  • Device, and connection information: device manufacturer, its model, its operating system information including its version and type of connection, its IP (Internet Protocol) addresses, the device's unique identifiers, geolocation marker and Internet service provider;
  • Information about your activity: visits to our or our Entities' apps and pages and statistical information on the number of visits or use, ad views, ad clicks, the ads location and type and retargeting data, which reveals previous interest in a product, app or website;
  • Web Surfer Information and/or inferences about the Web Surfer interests: information that allow us to personalize ads for Web Surfers, which we receive from our Entities, i.e., information about your interests, or demographic information.

Web surfers who receive ads served by iPromote retain their anonymity where iPromote is concerned. For our ad serving service, iPromote does not collect self-identifying information.

Purpose: iPromote collects the aforementioned data to provide our services. The IP address of an end user interacting with our services is retained separately from other data items, which prevents the possibility of identifying a specific user. We may collect the IP address and Technical Data of visitors to our website for the purpose of operating and improving our Site, performance and analytic purposes.

Lawful basis under the General Data Protection Regulation (GDPR): the collection of the above data is to perform our contracts, and for the necessity of processing for the purposes of our legitimate interests.

Where required under applicable law, we will require obtaining your consent ourselves or through our business partners.

B. Type of Information: Business Partner's Information

We may collect personal information from our business partners such as their persons of contact information, which includes their full names, telephone number and email address.

Purpose: Such information is collected for the purpose of engaging in business with such business partners and provide them our services and communicating with them. Should anyone be uncomfortable providing this information to iPromote, they can choose not to participate.

Lawful basis under the GDPR: the collection of data from our business partners is for the performance of our contract and the necessity of processing for the purposes of our legitimate interests.

iPromote may combine the non identifying information collected from other sources in order to optimize iPromote's services to its client and partners.

C. Type of Information: Information Received Directly From You

iPromote may also collect information we receive directly from you. If you contact us directly through our website or by email or in response to an ad that was served by iPromote, containing a survey, purchase agreement, or registration questionnaire, we may collect the information you provided us. Any personal information that a user voluntarily provides to an Advertiser is subject to the privacy policy of that Advertiser. We recommend that anytime you choose to voluntarily submit personal information online, you should first visit and review the privacy policy of that site.

Purpose: iPromote collects data directly from you in order to use your contact details and in order to respond to your inquiry and provide you with support, assistance or any other service that you requested.

Lawful basis under the GDPR: the collection of data directly from you is for the performance of our contract and the necessity of processing for the purposes of our legitimate interests.

D. Type of Information: Information We Receive From Third Parties Service Providers

Such information generally consist of contact information and other information the customer voluntarily provides. iPromote does not retain sensitive Personal Information.

iPromote may obtain Personal Information from third parties service providers such as landing page, call tracking, and call recording providers.

Purpose: iPromote utilizes the aforementioned third parties to allow iPromote or iPromote clients to receive communications from the customers and analyze the received data.

Lawful basis under the GDPR: the collection of data for third parties is for the performance of our contract and the necessity of processing for the purposes of our legitimate interests.

E. Type of Information: Recruitment Information

iPromote may collect information we receive directly from you or from a third party, who received the information from you, when you apply for a position with iPromote. Such information will usually include personal details (such as name, title, email, telephone, postal address) and  qualification data (including relevant education, experience and skills).

Purpose: iPromote collects this information to recruit employees or contract with relevant workers. iPromote may continue to store the applicant's relevant personal information for the period of time necessary to ensure exercising iPromote's rights or defending against claims.

Lawful basis under the GDPR: the collection of data for recruiting purposes is for the performance of our contract and the necessity of processing for the purposes of our legitimate interests.

Data Retention

Unless required otherwise by applicable law, iPromote retains Personal Information it may collect for as long as needed to provide its services, operate them, monitor them, and to comply with its legal obligations, resolve disputes and enforce agreements.

Does iPromote Share Your Personal Information?

iPromote will not share any personal information collected from you with third parties or any of our partners except in the following events:

  • Legal Requirement: iPromote will share your information if it is required to do so in order to comply with any applicable law, regulation, legal process or governmental request (e.g., to comply with a court order, comply with tax authorities, pursuant to law enforcement inquiries, etc.);
  • Third Party Service Providers: iPromote may disclose your information to trusted service providers in order to perform requested services on iPromote's behalf. For example, third party cloud and storage services, to store and retain your data. iPromote may transfer you to a third party's service provider site or platform in order to process required information required to perform iPromote's services, such as for billing purposes;
  • iPromote's Clients: iPromote may share your information as part of an analytics report it provides to its clients;
  • iPromote's Rights: iPromote may share your information, as required, in order to exercise its rights or enforce its policies and agreements and to investigate any potential violations, as well as to defend against legal claims;
  • Third Party Rights: iPromote may share your information, as required, in order to prevent harm to the rights of its users, business partners and any third party's rights, property or safety;
  • Business Transfers: iPromote may share personal information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
  • Online Identifiers: iPromote may share online identifiers with our advertising partner's and to detect fraud.

iPromote reserves the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by iPromote and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

Cookies and Web Beacons

Like most digital marketing solutions, iPromote uses "cookies" and other technologies to enhance users' experiences on the web, to deliver more relevant ads, and for ad delivery and reporting. We cannot use these technologies to personally identify you, and these technologies do not damage your system or files. iPromote uses these technologies to help recognize a unique computer or device so we are able to deliver relevant advertising and measure the impact of that advertising. The types of technologies used include:

  • Cookies – Cookies are small text files that contain a string of characters. iPromote uses cookies to change the sequence of the ad banners that are delivered to your web browser and to limit the number of times your web browser receives the same advertisement. Cookies are also used by our reporting system to estimate the total reach of an ad campaign, the number of times an ad is clicked on, and how many Web surfers visit an Advertiser's website.
  • Web Beacons – Web Beacons are used to help web publishers understand how visitors interact with their websites. Pixel tags are transparent images, iFrames, or JavaScript that are placed on a site. The use of a pixel tag allows a website to measure the actions of the visitor opening the page that contains the tag.

iPromote uses cookies and pixel tags primarily to: (i) report to iPromote's advertiser and Web site clients the estimated total reach of an ad campaign; (ii) report the frequency with which an ad was shown to a user and other measurement statistics; (iii) ensure that an ad displayed to a user corresponds to the correct click-through destination; (iv) deliver a series of advertisements in the proper sequence; (v) deliver advertisements that fall within certain categories such as sports, music, travel, food, etc.; and (vi) limit the number of times a browser is delivered the same advertisement. iPromote does not share personal information with third parties, other than as provided in this Privacy Policy.

Your Choices

iPromote firmly believes that every individual who uses the Internet should be able to make informed decisions with respect to individual privacy matters, including the use of cookies. Thus, we are happy to provide you with a number of choices. You can choose to accept or refuse cookies by changing the settings in your Internet browser. You can also opt to be warned before a cookie is put on your computer. You can also choose to periodically delete cookies from your computer's hard drive, clearing out all historical data that may have been saved from your previous online sessions. In addition, iPromote provides you the opportunity to opt-out of just iPromote's cookies by following the opt-out procedure set forth below.

The following table describes the categories of Cookies we use and why we use them:

Type of Cookie What these Cookies do Cookies Names and Source Purpose
Essential Cookies These cookies are necessary to provide you some of the features of iPromote website and services. Session ID (sid) Cookie that establishes a session between a user and the iPromote website for tracking and authentication (sign-on) purposes
Analytics Cookies These cookies are used by iPromote and third parties to collect information on how you use our website and services. Conversion (ctc) Cookie that helps register a conversion
Frequency (frq) Cookie that contains a numeric ad ID and a counter value that keeps track of how many times a browser renders an ad from iPromote within a given time window
Advertising Cookies These cookies are deployed by iPromote or third parties in order to deliver advertisements to you based on your personalized interests. Campaign (crt) Cookie that helps retarget based on a specific iPromote campaign ID
Category (cat2) Cookie that helps retarget based on a specific iPromote campaign ID
EDAA (edaa) Cookie that is placed if a user clicks an AdChoices link to inquire about opting-out of ad viewing
Hits (hits) Cookie that logs one click or conversion per impression to ensure that only one click or conversion occurs per impression
Last Viewed (lv) Cookie that contains a numeric ad ID and the most recent time viewed for a rendered iPromote ad
Opt-Out (optout) Cookie that enables a user to opt-out of receiving iPromote ad serving cookies

*The cookies listed above are iPromote proprietary cookies.

If you desire to "opt-out" of iPromote advertising cookies now, click here. Following the opt-out process, you will continue to have one iPromote cookie on your computer, but for all intents and purposes, it will contain only an "off switch" used merely to tell us not to put any new cookies on your computer.

iPromote is a member of the Digital Advertising Alliance (DAA) and adheres to the DAA principles for Interest Based Advertising http://www.aboutads.info/principles. The DAA establishes and enforces responsible privacy practices across industry for relevant digital advertising, providing consumers with enhanced transparency and control. Consumers may opt out of Interest Based Advertising. The DAA offers a Consumer Choice Page http://www.aboutads.info/choices/. To learn more, please visit http://www.aboutads.info.

In Europe, iPromote is a member of the European Interactive Digital Advertising Alliance (EDAA) and a signatory to the Self-Regulatory Principles for Online Behavioral Advertising (http://www.edaa.eu/european-principles/). The EDAA offers a Consumer Choice Page (http://youronlinechoices.eu) (opt-out). To learn more, please visit http://edaa.eu.

There are also two additional options for web users who wish to opt-out of receiving cookies. At any time, you can follow the simple procedures below to either manually delete cookies from your hard drive or automatically block the use of all cookies by changing a setting in your browser.

How Can Users Delete Cookies?

One way you can delete cookies stored on your computer, and therefore interrupt the process by which Web sites and advertisers collect non-personally identifiable information, is to delete all cookies on your computer's hard drive. This will delete cookies from our clients and everybody else. Depending on your Internet browser, you can delete all cookies in the following way:

Please consult the user manual or help file for your particular browser for any changes to the above process.

How Can Users Block Cookies?

One way you can stop cookies from being put on your computer is to block all cookies by disabling cookies in your Internet browser configuration. This will block cookies from our clients and everybody else.

Individual Rights Relating to Their Personal Information

It should be noted that certain jurisdictions allow their residents certain rights over their information including to review, edit, and limit the use and disclosure of their personal information, as follows:

European Union Residents

European Union residents have certain data privacy rights. In addition to the opt-out choice detailed above, European Union residents have the following rights:

  • The right to request access to the personal information iPromote collected from you;
  • The right to request the amendment of any inaccurate personal information relating to you;
  • The right to request the deletion of your personal information;
  • The right to restrict processing of your personal information;
  • The right to withdraw your consent to our processing of your personal information;
  • The right to data portability of your personal information.

California Residents

California residents have certain data privacy rights. In addition to the opt-out choice detailed above. Please see the CCPA Privacy Notice for further information.

Linked Sites

Advertisements delivered by iPromote on behalf of its clients can contain links to other sites. Please be aware that linked sites are not covered by this privacy policy although they may adhere to their own similar policies. iPromote does not assume any responsibility or liability for the actions, products, services and content of linked sites. We recommend that you visit and review the privacy policies of linked sites, as we have no control over information that is submitted to, or collected by, these third parties.

Contacting iPromote

iPromote openly volunteers its privacy practices. If you have any questions or you feel we are violating any privacy principle, please contact our designated Privacy Officer at privacy@ipromote.com.

iPromote has further committed to refer unresolved Privacy Shield complaints to the European Data Protection Authorities as an alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for more information or to file a complaint. The services of the European Data Protection Authorities are provided at no cost to you. If the European Data Protection Authorities finds us to be in violation of any privacy principle, we will correct the situation and stop processing the data of the user bringing the complaint.

iPromote also adheres to the IAB Europe OBA Framework and is committed to following the EDAA Good Practice Principles (http://www.youronlinechoices.eu/goodpractice). If you feel we are not adhering to these principles, please contact us at privacy@ipromote.com. If you think your inquiry has not been satisfactorily addressed, then you may follow the complaint procedures at http://youronlinechoices.com/uk/make-a-complaint.

U.S.-EU Privacy Shield Program

iPromote complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. iPromote has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. iPromote is committed to subject all personal data received from the EU to the principles of Privacy Shield, including: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

As required by the Privacy Shield Framework:

  • iPromote is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC);
  • Under certain conditions, individuals may invoke binding arbitration;
  • Promote is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
  • iPromote has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. We shall remain liable under the Principles if our agent processes such personal information in a manner inconsistent with the Principles, unless the iPromote proves that it is not responsible for the event giving rise to the damage.

Changing Our Privacy Practices

Please note that because of the changing nature of both technology and privacy laws, consumer needs, and our business, iPromote is committed to the constant monitoring and examination of its privacy practices, and may, from time to time, institute changes to its Privacy Policy. In the event that any material changes are made to the company's privacy practices, we will promptly make changes to this privacy policy and we will post these changes on this page so that you are always aware of what information we collect and how we use it. Regardless of any future changes, however, we will never use the information you submit under this current policy in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

Children's Privacy and Spam

As of April 21, 2000 the Children's Online Privacy Protection Act became effective. The regulations apply to the online collection of personal information from children under the age of 12. iPromote is very sensitive to the issue of children's privacy and makes every effort to protect the privacy of children using the Internet. iPromote's Web site, products, and services are not developed for or directed at children. Our policy is not to permit anyone under the age of 18 to do business with us. If you believe your child has provided iPromote with any personally identifiable data by registering at iPromote's Web site, please e-mail us at privacy@ipromote.com to have the data removed. We also request that all Web sites using our advertising network disclose in their privacy statements any and all information regarding the collection of information from children. In addition to the above, iPromote is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. 7701).

A Special Note About the European Union

Any Personal Information that we may collect according to this Privacy Policy is handled and treated in compliance with the EU general data protection regulation.

Security

iPromote takes appropriate precautions to protect our users' information. Your account information is located on a secured server behind a firewall. When you enter sensitive information (such as credit card number or your password), we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, go to http://en.wikipedia.org/wiki/Secure_Sockets_Layer). iPromote also has an internal security policy with respect to the confidentiality of customer and other data, limiting access only to those employees who we reasonably believe need to know such information for the purpose of performing their jobs. Please keep in mind, however, that the Internet is not a 100% secure medium. Therefore, although we use reasonable efforts to protect information, the possibility of somebody defeating our security measures does exist.

Cross-Border Data Transmission

iPromote may transfer the information it collects (including any Personal Information) outside the country in which it is collected or in which you reside, including to a country that may not offer the same level of protection for Personal Information as the country in which you reside. In such cases, we ensure to implement contractual safeguards to make sure the processed information receives an adequate level of protection when it is transferred between or among third party vendors. By providing Personal Information and engaging our services, you expressly consent to our use of the information in accordance with this Privacy Policy and to the transfer of your information to another country.

Disclosure

Except as otherwise restricted by law, regulation, or contract, iPromote reserves the right to publish or otherwise make public anonymous, aggregate, or summary information regarding users and campaigns run on behalf of our clients. We may share user-level data with clients. There also may be instances when we disclose information in our systems in order to protect the legal rights of iPromote or its employees, agents, and contractors; protect the safety and security of users and visitors to our Website; protect against fraud; or to comply with the law or legal process. If iPromote sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer information in our systems to a third party as part of that transaction.