Privacy Policy

This Privacy Policy explains how EngageClick, Inc, its subsidiaries and affiliated companies (collectively, "EngageClick" or "we", "us", "our") use end users ('you' or 'your') your personal and device-related information when (i) you view ads served by EngageClick on third party websites or mobile apps, and (ii) you visit the EngageClick website at www.engageclick.com (see section below called "EngageClick Website").

ENGAGECLICK ADVERTISING PLATFORM

WHAT IS THE ENGAGECLICK PLATFORM?

It is a technology platform facilitating the delivery of personalized, dynamic ad experiences that automatically adapts to audiences across all screens – mobile, video, online and OOH.

We partner with third party website publishers and mobile app developers to serve ads on their sites and in their apps. These ads are customized to their users' interests and geographic locations, which we infer from information we collect about how those users interact with sites and apps that have partnered with EngageClick (this type of advertising is often called "interest-based advertising" or "targeted advertising"). This enables our partnering publishers and developers to provide content-rich services that are more relevant to their users, often using the advertising revenues they generate to offer their services for free or at a subsidized cost.


WHAT INFORMATION DO WE COLLECT?

When you view an EngageClick ad on a site or an app that uses our services, we may collect information about your device or the ad that you have viewed. This information does not enable us to work out your identity in real life, but does enable us to recognize your device when you use other sites and apps that have partnered with us.

Specifically, we may collect:

(a) Information about your device

We may collect some or all of the following information about your device: device type (e.g. smartphone, tablet, etc.), operating system (e.g. iOS, Android, Windows, Blackberry), network provider, Internet (IP) address, which mobile browser you use (e.g. Safari, Internet Explorer etc.), the carrier user ID (a number uniquely allocated to you by your network provider), platform, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for Advertising, iOS Identifier for Vendors, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), Model, manufacture and OS version of device, session start/stop time, locale (specific location where a given language is spoken), time zone, and network status such as WiFi, the geo-location of your device (using GPS or other geo-location data) and the unique device identifier of your mobile device (a number uniquely allocated to your device by your device manufacturer).

(b) Information about the ad you have viewed

We also collect some or all of the following information about the ad you have viewed: (i) the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the website on which the ad appears); and (iv) certain information about post-click activity in relation to the ad (e.g. whether you proceed to purchase the product or service advertised).

On occasion, our partnering mobile publishers or app developers may also disclose to us information they have separately collected about you so that we can improve the relevance of the ads we serve on their behalf. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements. We do not use the information they provide to us for any purpose other than serving you with interest-based ads on their behalf.

There is certain data that although not personally identifiable we consider sensitive, such as viewing of sites with sexual content or information indicating a users' specific medical condition. We do not use these types of sensitive data from one site for tailoring ads at other sites across our network.

(c) EngageClick Platform

The EngageClick Platform also provides information to publishers and developers about how you use and engage with their app as well as how sites or apps are performing across different handsets, including but not limited to tracking conversions across multiple advertising networks.

EngageClick obtains this information as a result of data being sent via an SDK embedded by the publisher or developer in your app.

Each publisher and developer is responsible for obtaining all applicable consents to enable EngageClick to collect information from your device.


HOW DO WE USE INFORMATION THAT WE COLLECT?

We use the information we collect to display interest-based advertising customized to individuals’ inferred interests, preferences and locations, and to perform analysis aimed at improving our services and technologies. The information we collect also helps us to provide filtering options for publishers and developers to manage ads appearing on their sites and in their apps, and to provide targeting options for advertisers. This helps our publishers and developer clients, for example, not to present you ads that you have already seen, and helps our advertiser clients serve adverts that are most likely to be of interest to you.


WHO DO WE SHARE INFORMATION WITH?

 With Publishers, Developers and Advertisers

We share the information we collect from your visits to partnering sites and apps with our publisher, developer and advertiser clients. We anonymise this information using one-way hashing (i.e. scrambling) technology and encrypt it securely before sharing it. These measures preserve your anonymity and mean that our clients cannot identify you in real life from the information we share. Our clients use this anonymised information to better understand their site and app traffic usage so that they can refine and improve their services.

 With EngageClick Affiliates

We may also share your information among EngageClick affiliates so that we can better provide advertising that is relevant to you.

 Sharing Info with Third Parties

From time to time, we may need to disclose your information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our users. This may include exchanging information with other companies and organizations for fraud protection.

We may also share your personal information in connection with any merger, a sale of EngageClick assets, or a financing or acquisition of all or a portion of our business to another company. Whenever we share your personal information for this reason we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it commits to using your personal information only for the purposes for which you originally provided it.


INTERNATIONAL TRANSFERS

We may share your information with clients, affiliates and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EU resident, we may share your information with our non-EU clients or affiliates). While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take all reasonable measures to protect your information in accordance with this Privacy Policy and applicable legal requirements.


HOW DO WE KEEP INFORMATION SECURE?

EngageClick uses appropriate technical and organizational measures to protect the information it collects about you and your device. In particular, we anonymise all information we collect using one-way hashing technology and encrypt it securely before sharing it with any third parties.


HOW LONG DO YOU KEEP INFORMATION FOR?

We retain information collected on third-party applications and web sites for a period of 90 days, unless otherwise required by law. After 90 days we further anonymise the data by aggregating it before storing it for analytical purposes.


OPTING OUT OF INTEREST-BASED ADVERTISING

As described above, the information we collect does not enable us to work out your identity in real life. We use this information only to serve you with interest-based advertisements based on your inferred interests, preferences and location.

If you prefer not to receive this, you can opt out of EngageClick using your information for interest-based advertising purposes at any time by going to the EngageClick Opt Out page.

Please note that if you opt out of EngageClick using your information for interest-based advertising you may still receive "generic" ads from us that are not based on your inferred interests.


INFORMATION COLLECTED ON BEHALF OF THIRD PARTIES

EngageClick may offer advertising solutions to clients that include the collection of voluntary information from you as part of an advertisement, e.g. serving an ad that contains an advertiser questionnaire. All of the information that you voluntarily provide in response to the advertisement shall be collected by EngageClick and forwarded directly to the relevant client and will be governed by that client's privacy policies in place from time to time.

ENGAGECLICK WEBSITE

WHAT INFORMATION DO WE COLLECT?

To create an account on the EngageClick website we need to collect the following details;

username,

password,

email address,

country and preferred account type.

You can also provide us with other optional information, such as your name, picture, postal address, phone number, social network profiles, questionnaire responses, general business information, and other personal, biographical, or demographic info. This optional information is not necessary for you to use the EngageClick site or to maintain an account with us, but by sharing this information we can better serve you and improve your overall website experience.

If you provide the name and email address of a friend or colleague, we will use that information to send the individual a one-time invitation to visit or register with our site.


THE USAGE INFORMATION WE COLLECT

In addition to the personal information described above, we also collect certain information about your usage of the site. Specifically, our servers collect the following information automatically about your usage of the site:

 the type of web browser you use (e.g. Internet Explorer, Mozilla Firefox, Google Chrome or another)

 where you travel within the site (e.g. the pages that you visit within the EngageClick site)

 your browsing preferences, such as your screen size, resolution and other viewing preferences

 the links and adverts that you click on

 information about how you arrived at our site (e.g. whether you were directed to our site by a search engine or another third party website)

 information about how you leave our site (e.g. which website you visit immediately after visiting our site).

 We may use cookies to help us collect and store this information, as described in more detail below in the section headed "Does EngageClick use cookies?" and our cookie policy.


HOW DO WE USE THE INFO WE COLLECT?

We use the account information and other personal information you provide to manage your account, communicate with you, conduct business with you (e.g. reporting and payment), personalize the EngageClick website, comply with your requests, and inform you about products and services in accordance with your marketing preferences.

We use your usage information to analyze our web traffic, to figure out how often customers use parts of the site, to improve the site and generally to make it appealing to as many users as possible.


WHO DO WE SHARE INFORMATION WITH?

We will share your personal information only in the ways that are described in this privacy statement. We do not sell your personal information to third parties.

From time to time, we may need to disclose your information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our users. This may include exchanging information with other companies and organizations for fraud protection.

We may also share your personal information to companies that provide services to help us with our business activities (e.g. processing payments or submitting emails to you on our behalf), in connection with any merger, a sale of EngageClick assets, or a financing or acquisition of all or a portion of our business to another company. Whenever we share your personal information for this reason we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it commits to using your personal information only for the purposes for which you originally provided it.

You should also be aware that the information submitted to public areas, such as our blogs, may be read, collected, and used by others who access them.

If you interact with social media features on our site, such as the Facebook Like button, or use your social network credentials to comment on our blog, these features may collect information about your use of this site as well as post information about your activities on this site to your profile page. Your interactions with these Features are governed by the privacy policy of the company providing it.


INTERNATIONAL TRANSFERS

We may share your information with our affiliates and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EU resident, we may share your information with our non-EU clients or affiliates). While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take all reasonable measures to protect your information in accordance with this Privacy Policy and applicable legal requirements.


HOW DO WE KEEP INFORMATION SECURE?

We use appropriate technical and organizational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. We encrypt all information we collect and maintain this encrypted information securely on our servers behind a firewall. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.


HOW LONG DO YOU KEEP INFORMATION FOR?

We retain information for only as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless otherwise required by law.

Alcoholic beverages

Our policy

EngageClick restricts the promotion of alcoholic beverages and drinks that resemble alcoholic beverages. When promoting alcoholic beverages, you may not do any of the following:

 Violate applicable laws and industry standards for any location that your campaign targets

 Target individuals below the legal drinking age

 Imply that drinking alcohol can improve social, sexual, professional, intellectual, or athletic standing

 Imply that drinking alcohol provides health or therapeutic benefits

 Portray excessive drinking in a positive light or feature binge or competition drinking

 Show alcohol being consumed in conjunction with the operation of a vehicle of any kind, the operation of machinery, or the performance of any task requiring alertness or dexterity

Examples of what's allowed in some circumstances

The following types of alcohol-related promotions are allowed, provided that they meet the requirements stated in the policy and target only the countries that are explicitly listed as being permitted.

 Promotions for the sale of alcoholic beverages

We consider ads to be promoting the sale of alcoholic beverages when one or more alcoholic beverages are featured in the ad, and alcohol can be purchased on the destination site.

Not allowed: Advertising for the online sale of alcoholic beverages is not allowed to run in any countries not listed below. If your campaign targets only countries that are not listed, your ad will be disapproved.

Allowed: We allow advertising for the online sale of alcoholic beverages to run in the countries below.

Albania
Argentina
Australia
Austria
Belgium
Bosnia and Herzegovina
Brazil
Bulgaria
Cambodia
Canada
Chile
Colombia
Costa Rica
Cyprus
Czech Republic
Denmark
Ecuador
Estonia
France  
Germany
Ghana
Greece
Hong Kong
Hungary
Iceland
Ireland
Israel
Italy
Japan
Kenya
Latvia
Lithuania
Luxembourg
Malta
Mexico
Montenegro
Netherlands
New Zealand  
Nigeria
Panama
Peru
Philippines
Portugal
Puerto Rico
Romania
Senegal
Singapore
Slovakia
South Africa
Spain
Sweden
Switzerland
Uganda
Ukraine
United Kingdom
United States
Uruguay  


 Branding or informational ads promoting alcoholic beverages

Branding and informational ads include promotions which focus on alcoholic beverages, or spread awareness of alcoholic beverages, but which do not offer them for online sale.

Not allowed: Brand or informational advertising for alcoholic beverages is not allowed to run in any countries not listed below. If your campaign targets only countries that are not listed, your ad will be disapproved.

Allowed:We allow brand or informational advertising for alcoholic beverages to run in the countries below

Albania
Argentina
Australia
Austria
Belgium
Bosnia and Herzegovina
Bolivia
Brazil
Bulgaria
Cambodia
Canada
Chile
Colombia
Costa Rica
Cyprus
Czech Republic
Denmark
Dominican Republic
Ecuador
El Salvador
Estonia
France  
Germany
Ghana
Greece
Honduras
Hong Kong
Hungary
Iceland
Ireland
Israel
Italy
Japan
Kenya
Latvia
Lithuania
Luxembourg
Malta
Mexico
Montenegro
Netherlands
New Zealand
Nicaragua
Nigeria  
Panama
Paraguay
Peru
Philippines
Portugal
Puerto Rico
Romania
Senegal
Singapore
Slovakia
South Africa
South Korea
Spain
Sweden
Switzerland
Taiwan
Uganda
Ukraine
United Kingdom
United States
Uruguay
Venezuela  


What you can do

Here's more detail about each violation and what you can do if your ad is disapproved or your site is suspended:

Read the policy above to see the types of alcohol-related content that we don't allow as well as country-specific restrictions for places that your campaign targets. Here's some information to keep in mind:

Disallowed content: See the top of this page for the ways in which you can't promote alcohol. For example, you can't violate local law, target individuals below the legal drinking age, or portray excessive drinking in a positive light.

Non-alcoholic beverages: This policy also applies to products marketed in the same way as alcoholic beverages, regardless of alcohol content. If you promote low-alcohol and non-alcoholic beer, wine, and cocktails, make sure that your ad and site meet the requirements above.

Country requirements: Your ad can be disapproved if your campaign targets only locations where we don't allow that type of alcohol-related content.

Target a different location: If your ad meets the basic policy requirements but not those for the countries that your campaign targets, you can choose to edit your location targeting to run your ads somewhere else where they do meet our requirements.

Change your ad's landing page. If the landing page that your ad leads to violates this policy, please change it to make it comply. Once you've fixed the violation, resubmit your ad using the steps below.

Remove that content from your ad. If your ad violates this policy, please edit it to make it comply.


What happens if you violate our policies

Ad disapproval: Ads that don't follow this policy may get disapproved. A disapproved ad won't be able to run until the policy violation is fixed and the ad is approved.

Domain disabling: We may suspend websites that violate this policy, meaning that the website can no longer be advertised until the problem is fixed.

Account suspension: An account may get suspended if you have several violations or a serious violation. If this happens, all ads in the suspended account will stop running, and we may no longer accept advertising from you. Any related accounts may also get permanently suspended and your new accounts may get automatically suspended at setup.

To ensure a safe and positive experience for users, EngageClick requires that advertisers comply with all applicable laws and regulations addition to our policies. It's important to familiarize yourself with and keep up to date on these requirements for the places where your business operates, as well as any other places your ads are showing. When we find content that violates these requirements, we may block it from appearing, and in cases of repeated or serious violations, you may no longer be able to advertise with EngageClick.

US Specific Guidelines:

For complete listing of prohibited practices in the US, see the following guidelines

Wine:

http://www.gpo.gov/fdsys/pkg/CFR-1998-title27-vol1/pdf/CFR-1998-title27-vol1-sec4-64.pdf

Distilled Spirits:

http://www.gpo.gov/fdsys/pkg/CFR-2012-title27-vol1/pdf/CFR-2012-title27-vol1-sec5-65.pdf

Malt Beverages:

http://www.gpo.gov/fdsys/pkg/CFR-2012-title27-vol1/pdf/CFR-2012-title27-vol1-sec7-54.pdf

GENERAL

DOES ENGAGECLICK USE COOKIES?

We use cookies and web beacons to help us collect some of the information we describe above, to provide website functionality and advertising to you, and to save you having to provide information you have already given us on subsequent visits to our site.

For more detailed information about the technologies we use and your rights to control those cookies, please visit our cookie policy.


WHAT ABOUT CHILDREN?

We do not knowingly collect any personal information about children under the age of 13. If we become aware that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database.


WHAT ABOUT OTHER WEBSITES?

Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.


CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.


YOUR RIGHTS

Much of the information we hold is purely technical in nature, and relates to the devices that interact with our website or our ads rather than being "personal" in nature about any individual. Information on how to refuse use of this information for interest-based advertising purposes is provided above in the section "Opting Out of Interest-based Advertising" above.

Where we do hold limited personal information about you (such as personal information about an EngageClick account you have with us), you can ask us for access to this personal information, to correct or update any inaccurate personal information we hold, to stop sending you direct marketing or to stop using your personal information altogether.

If you would like to exercise any of these rights, you may be able to make the update within your account settings or by contacting us using the details provided below.


CONTACT US

If you have any questions about this Privacy Policy, please contact us at: privacy@engageclick.com.

LAST UPDATED: Aug 2015