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Privacy Policy
Effective Date: June 02, 2021
Let Actions Speak LLC (“we, “us”, “our”, or “Income Inflow”) provides digital marketing, advertising, and consulting services for its customers (the “Services”). This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share information (i) on our corporate website at https://www.incomeinflow.com or any Income Inflow-owned website (collectively the “Website”); and (ii) through our Services, and applies to all individuals who use the Website or whose information is otherwise provided to, or collected by us, in connection with our Website and the Services.
Income Inflow respects the privacy of its online visitors and customers of its Website and Services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation (“GDPR”) and the Swiss and EU Privacy Shield Frameworks.
For the purposes of users of the Website located in the EU, we are the controller of any information we may collect when you visit our Website. Our Data Protection Officer can be contacted at [email protected] for the purposes of the General Data Protection Regulation (“GDPR”). Please read this policy carefully so that you understand your rights in relation to, and how we will collect, use and process, your information.
Definitions
Wherever we talk about Personal Data below (“Personal Data”), we mean any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to Personally Identifying Information, for example:
- Your account registration information on our Website;
- When you request any support from us or report any problem to us;
- Information provided from using certain services or features;
- Information from completion of survey or questionnaire;
- Technical information, including the Internet protocol (IP) address used;
- Your login information, browser, time zone setting, browser plug-in types, and versions, operating system, and platform;
- Details of any transactions, purchases, and payments you made;
- Your general interaction with the Website, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Website, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information;
- information received from third parties, such as business partners, sub-contractors, payment and delivery services, referrals by other users.
Income Inflow also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. We may share anonymous data, aggregated or not, with third parties. Please be aware that we may choose to permit third parties to offer subscription and/or registration-based services through the Website. We shall not be responsible for any actions or policies of such third parties and you should check the applicable privacy policy of such party when providing personally identifiable information.
By using the Website, you signify your assent to our Privacy Policy. If you do not agree to this Policy, please do not use the Website.
Section 1: Our Corporate Website
This section of the Privacy Policy describes how we collect, use, and share information collected on our Website.
Information Collection
We may collect a variety of information when you visit our Website. We collect certain information if you contact us, request our services, or otherwise provide it to us, and in each instance only to the extent you provide us with your personal information. This information we collect includes: your name, email address, phone number, and any other such information you directly provide to us.
We may also collect certain technical information when you visit the Website. This type of information includes your IP address, country, city, browser type, operating system, service provider, the areas you visit on the Website, time and date of your visit, and Google Analytics client ID. We may collect this technical information through cookies, web beacons, or other similar technologies. We may combine your IP address and other technical information together.
Types of Data Collected
Personal Data
While using our Website and Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Basic Account Data
When setting up an account, we will collect your email address and country of residence. You are also required to choose a user name and a password. The provision of this information is necessary to register a user account. You are responsible for keeping this password confidential. We ask you not to share your password with anyone.
During setup of your account, the account is automatically assigned a number (the “ID”) that is later used to reference your user account without directly exposing Personally-Identifying Information about you.
Usage Data
Usage Data is collected automatically when using the Website.
Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Website or when you access the Website by or through a mobile device.
Transaction and Payment Data
In order to make a transaction online, you may need to provide payment data to us to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date, and security code) to us, which we will process and transmit to the payment service provider of your choice to enable the transaction and perform anti-fraud checks. Likewise, we will receive data from your payment service provider for the same reasons.
Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others, e.g. in forums, chats, or when you provide feedback or other user-generated content. This data includes:
- Information that you post, comment or follow in any of our content and services;
- Information sent through chat;
- Information you provide when you request information or support from us or purchase content and services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;
- Information you provide to us when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details.
Tracking Technologies and Cookies
We use “cookies”, which are text files placed on your computer, to help us analyze how users use our services, and similar technologies (e.g. web beacons, pixels, ad tags, and device identifiers) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics or website functionality.
The use of cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our Website. When you visit any of our websites or services, our servers log your global IP address, which is a number that is automatically assigned to the network your computer is part of.
If you leave a comment on our Website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no Personal Data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no Personal Data and simply indicates the post ID of the article you just edited. It expires after 1 day.
We use cookies and similar tracking technologies to track the activity on our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our Website may use cookies.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
- Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: us
Purpose: These cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: us
Purpose: These cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: us
Purpose: These cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
How We Use Information
As it is in our legitimate interests to be responsive to you, provide the services on our Website, and to ensure and improve the proper functioning of our Website, we may use any of the information we collect for the following purposes:
- To respond to your inquiries and requests and otherwise communicate with you;
- To provide you with any services you request;
- For internal purposes, such as recordkeeping, and to operate our business;
- To operate and improve the Website, including to monitor the usage of our Website;
- To perform analytics and research;
- In connection with a corporate sale, merger, acquisition, or other business transaction or transfer of all or part of our assets;
- For business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred;
- To comply with law and to maintain the security of the Website, including to enforce our Terms of Service, exercise or defend legal claims and to protect our rights or the rights of third parties;
- To manage your account: to manage your registration as a user of the Website. The personal data you provide can give you access to different functionalities of the Website that are available to you as a registered user;
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Website;
- To contact you: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
- For content recommendations: we may process Personal Data so that content, products and services shown on the pages and in update messages displayed when launching the Website can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience.
- For email marketing: subject to your separate consent or where explicitly permitted under applicable laws on email marketing, we may send you marketing messages about products and services offered by us or our partners to your email address. In such a case we may also use your collected information to customize such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed;
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
- To detect violations: we collect certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of the applicable laws (“Violations”). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations;
- For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website and Services, marketing and your experience;
- As otherwise disclosed at the time of collection or use.
Information Sharing
We may share your personal information in the following situations:
- With service providers: we may share your personal information with service providers to monitor and analyze the use of our Website, to contact you. Visitor comments may be checked through an automated spam detection service;
- For business transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;
- With affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us;
- With business partners: we may share your information with our business partners to offer you certain products, services or promotions;
- With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile;
- With your consent: we may disclose your personal information for any other purpose with your consent.
Who Has Access to Data
Income Inflow and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed above. This includes our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only). In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
We may share your information with our personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfillment of your order, the processing of your payment and the provision of support services); persons under a duty of confidentiality to us; or persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world.
We make certain data related to your User Account available to other users. This information can be accessed by anyone by querying your ID. At a minimum, the public persona name you have chosen to represent you is accessible this way. The accessibility of any additional info about you can be controlled through your user profile page; data publicly available on your profile page can be accessed automatically. While we do not knowingly share Personally Identifying Information about you such as your real name or your email address, any information you share about yourself on your public profile can be accessed, including information that may make you identifiable.
We may share the types of information described above with the following third parties:
- Advertising, marketing, payment processing, and email service providers and professional advisers that perform services on our behalf including: Salesforce, LinkedIn, TikTok, YouTube, Twitter, Pinterest, Instagram, Facebook, Google Search Console, Bing Webmaster Tools, and Google Analytics;
- To our affiliates or otherwise within our corporate group;
- In connection with a corporate sale, merger, acquisition, or other business transaction or transfer of all or part of our assets;
- Pursuant to a subpoena, court order, governmental inquiry or other legal process, or as otherwise required by law, or when we believe necessary to exercise or defend legal claims or protect our rights or the rights of a third party;
- We may share your Personal Data with our third party providers that provide customer support services in connection with goods, content and Services distributed via us. Your Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary for performing customer support services;
- In accordance with internet standards, we may share certain information (including your IP address and the identification of content you wish to access) with our third party network providers that provide content delivery network services and server services in connection with us. Our content delivery network providers enable the delivery of digital content you have requested, by using a system of distributed servers that deliver the content to you, based on your geographic location;
- We may allow you to link your user account to an account offered by a third party. If you consent to link the accounts, we may collect and combine information you allowed us to receive from a third party with information of your user account to the degree allowed by your consent at the time. If the linking of the accounts requires the transmission of information about your person from us to a third party, you will be informed about it before the linking takes place and you will be given the opportunity to consent to the linking and the transmission of your information. The third party’s use of your information will be subject to the third party’s privacy policy, which we encourage you to review;
- To enforce our Terms of Service; and
- With your consent or as otherwise disclosed at the time of data collection or sharing.
We may also share information with third parties that has been anonymized or aggregated. We do not sell information collected through the Website to third parties.
Message boards, forums and/or chat areas enable users to exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available online; therefore, you are doing so at your own risk; and that such information can be collected, correlated and used by third parties and may result in unsolicited messages from other posters or third parties and these activities are beyond our control. If your Personal Data is posted on one of our community forums against your will, please use the reporting function or contact us at [email protected] to request its removal.
Social Media Tools and Links to Other Websites
The Website may provide links to other websites that we do not control. We encourage you to review the privacy policy of those websites you may visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.
Our Website may include social media tools or “plug-ins”, such as social networking and blogging tools offered by third parties. These social media companies are not affiliated with us and we have no control over the information they collect. These social media companies may collect information about you and may use and share such information in accordance with your social media account settings, including by sharing such information with the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the social media companies that provide those features. We encourage you to carefully read the privacy policies of any social media accounts you create and use.
If You decide to register through or otherwise grant us access to a third-party social media service, we may collect Personal Data that is already associated with your third-party social media service’s account, such as your name, your email address, your activities or your contact list associated with that account.
You may also have the option of sharing additional information with us through your third-party social media service’s account. If you choose to provide such information and personal data, during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this Privacy Policy.
Comments
When visitors leave comments on the Website, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the Website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Website can download and extract any location data from images on the Website.
Embedded Content From Other Websites
Articles on this Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
We use Google Analytics to improve the performance of the Website and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you visit our Website or use our Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
How long do we store your data after you visit our Website?
We will store your information as long as necessary to fulfill the purposes for which the information is collected and processed or — where the applicable law provides for a longer storage and retention period — for the storage and retention period required by law. In particular, if you terminate your user account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage. All your data and credits will be lost after deletion.
You can request deletion of your information by following the process set out in Section 3 below. Unless required by law, all data provided by you to us through our Website will be deleted no later than two (2) years after the date of disclosure. In cases where Personal Data cannot be completely deleted in order to ensure the consistency of the system, the user experience or the community, your information will be permanently anonymized. Please note that we may be required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our Website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other Legal Requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation;
- Protect and defend the rights or property of our company;
- Prevent or investigate possible wrongdoing in connection with the Website or Services;
- Protect the personal safety of users of the Website or the public;
- Protect against legal liability.
Children’s Privacy
Our Website and Services do not address anyone under the age of 18. Minors or people below 18 years old are not allowed to use this Website. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
Section 2: Income Inflow Marketing Services
This section of our Privacy Policy describes how we collect, use, and share information through our Services.
We ensure the data we collect from our affiliates and ad technology partners (as further described in The Information We Collect) is processed with your consent or legitimate interests, as applicable.
The Information We Collect
Through the provision of our Services we collect various types of information from our customers and ad technology partners to perform the Services, including from:
- Our Customers, who may provide advertising IDs, IP addresses, and hashed email addresses;
- Directors, officers, employees, contractors, and/or agents of our Customers, who may provide their name, title, email address, login details, information about their device, such as device identifier, model, network provider, browser type, language and IP address, and usage of the Services, such as pages viewed, date/time stamps and searches performed;
- Our Affiliates, who may provide information about your device, such as device identifier, model, network provider, browser type, language, IP Address, Information about mobile application usage, how you interact with applications you use and advertising you see, city level location information, device type, information about the app, such as the version, information about your mobile advertising identifiers such as your advertising ID and other general demographic information about you, including interests, age, and gender;
- Mobile Measurement Partners (MMPs), which measure how you interact with an advertisement and may provide us with impressions, clicks, time zone, city, language, conversion duration, connection type, application version, and level of interaction and your advertising ID; and
- Publishers (i.e. the owners of the applications and websites you use), Ad exchanges, Ad Networks, Supply Side Platforms, Direct Marketing Platforms and other ad technology companies, who assist with providing targeted advertisements, may provide information about your device, such as device identifier, model, network provider, browser type, language, IP Address, information about mobile application usage, how you interact with applications you use and advertising you see, city level location information, device type, information about the app, such as the version, information about your mobile advertising identifiers such as your advertising ID and other general demographic information about you, including interests, age, and gender.
How We Use the Information We Collect
We use the information we collect through the Services on the basis of consent or as necessary for our (or those of our customers’) legitimate interests, in running and improving our ad technology business to select and deliver targeted advertisements to a user’s browser or mobile apps, as described below:
- We use information for our (or those of our customers’) legitimate interests, including to:
- Provide, build and improve the Services, including to provide customer users with access to the Services and provide support;
- Build segment profiles for our customer’s marketing and advertising purposes, where the segment profiles are built exclusively for the specific customer who provided your IP address, cookie ID, and/or hashed email address to allow Income Inflow to show interest based ads to you on behalf of the customer, and are not used to provide services to other customers;
- Engage in analytics and research;
- Comply with law, prevent fraud, enforce our agreements, exercise or defend legal claims and to protect our rights or the rights of third parties;
- Provide reporting, attribution and frequency capping for our customers’ advertising campaigns;
- Communicate with our customers, including providing information about current or future marketing opportunities, updates about our company or our Services, release updates, webinars, and events we are hosting; and
- In connection with a corporate sale, merger, acquisition, or other business transaction or transfer of all or part of our assets.
- We also use information when individuals provide their consent, including to serve interest-based advertising on an individual’s desktop, mobile, and/or Connected Television device.
Where we receive your IP address, cookie IDs, or hashed email address from our customers in order to provide you with advertisements that may be of interest to you, we process this information pursuant to a written contract with our customers, and we do not retain, use, or disclose your IP address or cookie ID for any purpose other than for the specific purpose of performing the Services. We do not disclose any information we receive from customers to any third parties, except solely as necessary for us to perform our contractual obligations with our customers and provide the Services.
We may share the information we collect through our services with the following third parties:
- Facebook: 1 Hacker Way, Menlo Park, CA 94025
- Google: 1600 Amphitheatre Parkway, Mountain View, CA 94043
- Stripe: 185 Berry Street, Suite 550, San Francisco, CA 94107
- PayPal: 2211 N 1st St, San Jose, CA 95131
- TikTok
- YouTube
We require our customers to comply with all applicable laws, rules, and regulations, which includes providing required notices, obtaining any necessary consents, providing any necessary opt out disclosures, facilitating the exercise of your data subject rights, and complying with all other applicable data privacy laws.
In order to be able to serve interest based advertisements that you may wish to see, we may combine data and link your activities across your devices and on the website pages of our customer who provided your IP address, cookie ID, or hashed email address. We obtain this information through your IP address, using cookie tracking technology, or directly from our customers. We also may use your IP address and cookie ID for advertising campaign performance purposes on behalf of the customer who provided this information. Your IP address and cookie ID is used by us internally and is not shared with any third parties, except as provided below.
Information Sharing
We may share the types of information described above with the following categories of third parties for the following purposes:
- To our service providers that perform or enhance our Services on our behalf, including for cloud storage purposes, analytics and research purposes, to help our customers understand how their users are engaging with their ads, to provide general demographic information about the users who are most engaging with certain types of ads on our customers’ desktop or mobile properties, or to obtain information about what kind of ads are published on our customers’ desktop or mobile properties;
- To our customers to provide the Services, including customizing advertising and reporting on the performance of that advertising;
- Pursuant to a subpoena, court order, governmental inquiry or other legal process, or as otherwise required by law, or when we believe necessary to exercise or defend legal claims or protect our rights or the rights of a third party;
- To investigate, prevent, or take action regarding alleged or actual illegal activities, violations of our agreements;
- To publishers (i.e. the owners of the applications and websites you use), Ad exchanges, Ad Networks, Supply Side Platforms, Direct Marketing Platforms and other ad technology companies, who assist with providing targeted advertisements for the purpose of serving you with contextual and/or targeted ads that are relevant to and may interest you, as necessary to perform the Services to our customers;
- Any other purposes disclosed to you at the time we collect your information or that we otherwise collect with your consent; and
- As part of a corporate sale, merger, acquisition, or other business transaction or transfer of all or part of our assets, including as part of a bankruptcy proceeding.
We do not sell information collected through the Services to third parties.
Where do we store your Personal Data?
As we are a United States company, any information provided to us, will be stored, processed, and transferred within, or to, the United States. It may also be processed by third parties who operate outside of your jurisdiction. Please be aware that the US and jurisdictions other than the one in which you are located may not have the same data protection laws as your own jurisdiction.
By submitting your personal data you agree to this transfer, storing or processing of data outside of your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy.
Your Personal Data is also processed by staff or service providers operating outside the EEA in the United States, who work for us.
Where we receive your information from publishers, advertisers or other ad technology partners, and they are located in the UK or EEA, we rely on standard contractual clauses for such transfers.
Your Choices and Opting Out of Interest Based Advertising
As described above, as part of our Services we receive IP addresses, cookie IDs, and/or hashed email addresses from our customers who collected this information from your previous visit to their website or application. We receive this information to make inferences about your interests in order to provide advertising relevant to you based on these interests. This practice is known as interest-based advertising.
You can use your device settings, such as “Limit Ad Tracking,” to exercise choice regarding our collection and use of information for interest-based advertising from websites and mobile applications on your device. You also have the following opt-out choices:
- NAI Opt-Out
Click here if you would like further information regarding the DAA principles and here if you would like information about the NAI Code of Conduct. To receive more information about your choices, including to opt out of receiving interest-based ads from many third parties, please go to: http://optout.aboutads.info/. For more information about opting out on mobile devices, please go to: https://www.networkadvertising.org/mobile-choice. - Browser Opt-Out – Do Not Track
Many browsers (including Internet Explorer, Firefox, and Safari) allow you to set a Do Not Track (DNT) signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. We follow DNT settings. You can usually access your browser’s DNT option in your browser’s preferences.
Note that if you exercise choices regarding interest-based advertising you will still see advertising in websites and mobile apps, but those ads may be less relevant to your interests. Data may still be collected from your device with your consent for purposes other than interest-based advertising after you make your choices. If you use different devices, or reset your device identifier, you may need to make your choices again.
Retention of Data
Income Inflow stores data collected to provide the Services for a rolling period of two (2) years from the last website visit of our customers’ websites. Reporting data (which does not contain any Personal Data), is stored for the duration of the contract we have with our customers. Reporting data may be deleted at the customer’s request, and, unless required by law, two (2) years after termination of the Agreement. If our contract terminates with a customer, Income Inflow does not further collect or use any information received from the customer.
In cases where Personal Data cannot be completely deleted in order to ensure the consistency of the system, the user experience or the community, your information will be permanently anonymized. Please note that we may be required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
Section 3: Other General Privacy Practices
Data Security
We implement reasonable security measures to help protect the security of information we collect through the Website. However, please be aware that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.
Your Rights
In certain circumstances you may have rights in relation to the Personal Data we hold about you. We set out below an outline of, and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email [email protected]. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
Access
You have the right to know whether we process Personal Data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge information on whether your Personal Data is retained, access to and/or duplicates of the Personal Data retained. If you have an account on this Website, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us.
Portability
In certain circumstances, you have the right to receive or ask us to provide your Personal Data to a third party in a structured, commonly used and machine-readable format, although we will not provide you with certain Personal Data if to do so would interfere with another’s individual’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person) or where another exemption applies (we can only do so where it is technically feasible; we are not responsible for the security of the Personal Data or its processing once received by the third party).
Correction
You have the right to require us to correct any Personal Data held about you that is inaccurate and have incomplete data completed. If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected.
Erasure
You may request that we erase the Personal Data we hold about you in certain circumstances e.g. where you believe it is no longer necessary for us to hold the Personal Data or object to our processing. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
You may request for the deletion of your Personal Data through the deletion of the user account. As a result of deleting your user account, you will lose access to services, including the user account, subscriptions and service-related information linked to the user account and the possibility to access other services you are using the user account for.
In some cases, deletion of your user account, and therefore Personal Data deletion, is complicated. In some cases, considering the complexity and number of the requests, the period for Personal Data erasure may be extended, but for no longer than two further months.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances.
Objection or Restriction of Processing
You have a right to require us to stop processing the Personal Data we hold about you in certain circumstances (and require us to delete it or continue to store it). Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process or retain such data or if we need to retain it in relation with any legal claims.
If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR, in particular if the data is necessary for the establishment, exercise or defense of legal claims.
Withdrawal of Consent
Where you have provided your consent to us processing your Personal Data, you can withdraw your consent at any time by contacting us at [email protected].
In cases where Personal Data cannot be completely deleted in order to ensure the consistency of the system, the user experience or the community, your information will be permanently anonymized. Please note that we may be required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
If you withdraw your consent on which a processing of your Personal Data is based, we will delete your Personal Data without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
Rights for California Residents
If you are a California resident, please read our Privacy Notice for California Residents for more information about your privacy rights.
Objection to Marketing
At any time, you have the right to object to our processing of data about you in order to send you promotions, special offers and marketing, including where we build profiles for the customer who provided us with your information, and we will stop processing your data on behalf of the customer.
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the “unsubscribe” link provided in every marketing email. Notwithstanding any opt out of promotional or marketing emails by you, we reserve the right to contact you regarding account status, changes to the user agreement and other matters relevant to the underlying service and/or the information collected.
Complaints
In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at [email protected] and we will endeavor to deal with your request. If you are a current resident in the EEA or UK, this is without prejudice to your right to launch a claim at the data protection supervisory authority in the UK or the EEA country in which you live or work where you think we have infringed data protection laws.
Changes to This Notice
If we make changes to this Privacy Policy, we will post the new policy here and take any other steps required by applicable laws. We encourage you to periodically check back to remain up to date on our privacy practices.
Contact Us
If you have questions, comments, or concerns about this Privacy Policy, please email us at [email protected].
Our address:
Let Actions Speak LLC
6339 Barsac Pl
Rancho Cucamonga, CA, 91737
