Please read this Policy carefully. If you do not want us to collect, use, or disclose your Personal Data in the ways described in this Policy, please do not attempt to access, use, or otherwise interact with our Platform, provide us with your Personal Data, or authorize any third party to make your Personal Data available to us. By accessing, using, or interacting with our Platform, or otherwise providing, or authorizing a third party to provide, us your Personal Data, you acknowledge that you understand that we may use your Personal Data as described in this Policy. If you have any questions about how we collect, use, protect, or disclose your Personal Data in connection with our Platform, please contact us by email at [email protected]
PERSONAL DATA PROCESSED ON BEHALF OF OUR CLIENTS
PERSONAL DATA AND OTHER INFORMATION WE COLLECT
Our primary goals in collecting Personal Data are to provide and improve our Platform, to conduct our operations, to communicate with individuals, and to enable visitors to our Platform to easily navigate it. This section describes the Personal Data we collect through or in connection with our Platform.
When we refer to “Personal Data” in this Policy, we mean information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
Categories of Personal Data We Collect
Depending on how you access, use, or otherwise interact with our Platform, we, or third parties acting on our behalf, may collect the following categories of Personal Data about you:
- identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, unique personal identifier, government-issued identification number, online identifier, IP address, and other similar information;
- Platform account information, such as your username, password, account activity, and other similar information;
- online identifiers you use, such as your username, social media handles, and other similar information;
- communication information, such as information contained in voice mails, chats, emails, and other similar information;
- location information, such as where you live, where you are located, and other similar information; and
- other information you or third parties provide us.
Other Information We Collect
Depending on how you access, use, or interact with our Platform, the Usage Data we, or third parties acting on our behalf, collect may include:
- device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier, and other similar information associated with a computer or mobile device used to access, use, or interact with our Platform;
- information about interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send, and other similar information associated with activities on our Platform;
- information automatically collected by cookies and other tracking technologies deployed through or in connection with our Platform; and
- any other information that a computer or mobile device automatically sends when it connects to a website or an online application.
HOW WE COLLECT PERSONAL DATA
We collect Personal Data from various sources, which vary depending on the context in which we collect or use that Personal Data. This section describes the sources of Personal Data we, or third parties acting on our behalf, collect through or in connection with our Platform.
Directly From You
When you access, use, or otherwise interact with us or our Platform, including, but not limited to, requesting more information about us or otherwise communicating with us, we will collect the Personal Data you elect to provide us. In some instances, we may ask you to provide specific Personal Data. In some instances, the Personal Data we request is required for a particular feature of our Platform. If you do not provide us with such required Personal Data, you will not be able to use the applicable feature. There a several reasons why Personal Data may be required for a particular feature, including, without limitation, where we are legally required to collect the Personal Information and where it would be impossible for the feature to operate without the required Personal Data.
From Third Parties
We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our Service Providers, advertising networks, and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:
- We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with our Platform (“Service Providers”). Service Providers may include, without limitation, third parties that host our Websites or Offerings and third parties that provide us services related to emails and communications we send and receive.
- We, or third parties acting on our behalf, may receive Personal Data about you from our affiliates and other business partners. This Personal Data may include, without limitation, information related to interaction with our affiliates and other business partners and/or your access to, use of, or interaction with the services and products they provide.
- We, or third parties acting on our behalf, may receive Personal Data about you from other third parties, such as other users of our Platform, those that refer you to our Platform; and those on whose behalf you access, use, or interact with our Platform.
Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more third parties.
HOW WE COLLECT USAGE DATA
We, and third parties acting on our behalf, collect Usage Data in a variety of ways. Some Usage Data, such as the IP address of a device attempting to access, use, or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Data, such as information about what features of our Platform are popular, help us to improve and advertise our Platform. This section describes the primary ways Usage Data is collected in connection with our Platform.
When you access, use, or interact with our Platform, the systems we use to make our Platform available to you record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected.
Other Tracking Technologies
We may collect Usage Data through web beacons, clear gifs, pixel tags, or other similar technologies. These technologies are electronic images that may be used on or in connection with our Platform, including in emails we send. We use these technologies to operate and improve our Platform, deliver cookies, count visits, understand usage, and observe data on email deliver, open rates, click rates, bounces, unsubscribes, and other information.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or changes in applicable laws.
HOW WE USE PERSONAL DATA
We use Personal Data for various purposes to operate and improve our Platform and to conduct our business operations. This section describes the primary purposes for which we use Personal Data.
We may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers, and events via push notifications, e-mail, and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners, on and off our Platform. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Data” section below.
We may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) sending you emails to provide you with alerts and updates about your engagement with our Platform; (5) conducting statistical or demographic analysis; (6) complying with legal and regulatory requirements; (7) customizing your experience with our Platform; (8) protecting and defending Campaign Nucleus against legal actions or claims; (9) preventing fraud; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (12) those you authorize or instruct us to do; and (13) other business purposes permitted under applicable law.
No Additional Collection or Use
We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated, or incompatible purposes without providing you with notice.
Please note, we may use and disclose aggregated, anonymized, or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purpose, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our collection, creation, use, storage, disclosure, and protection of such Anonymized Data is not subject to this Policy.
OUR DISCLOSURES OF PERSONAL DATA
To operate our Platform, provide our Offerings, and to otherwise conduct our business operations, we may share Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties. This section describes the third parties with whom we may share Personal Data.
We may share Personal Data with our Service Providers in connection with the services the provide to us, including, without limitation, marketing, data hosting, and fraud protection and prevention. We require these Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which it was provided to them.
Affiliates and Business Partners
We may share Personal Data with our Marketing Partners to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners, on and off the Platform.
We may share Personal data with government and law enforcement officials or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available, or to comply with applicable laws.
Other Third Parties
We may share Personal Data with any third party to whom you consent or instruct us to provide your Personal Data.
HOW TO MANAGE YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data. This section describes the mechanisms available to you to control the Personal Data we collect, use, store, or disclose about you.
To update any Personal Data you have provided to us, update your preferences, or otherwise contact us about our use of your Personal Data, please email us at [email protected]
For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.
If you do not want us to use your Personal Data to deliver targeted advertisements to you according to our target audience preferences, you can opt out by sending us an email with your request to [email protected]. We do not control third parties’ collection or use of your Personal Data to serve interest-based advertising. However, these third parties, which may include our Marketing Partners, may provide you with ways to choose not to have your Personal Data used to deliver targeted to you according to their target audience preferences. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org, and from members of the Digital Advertising Alliance (“DAA”) on their website, located https://youradchoices.com. Please note, even if you opt out from receiving targeted advertisements, you may still see advertisements based on factors such as your general location derived from your IP address, your browser type, and your search terms.
PROTECTING YOUR PERSONAL DATA
We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the use of email and the internet. Your Personal Data and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.
We do not direct or target any piece of our Platform to children under the age of 13. If we learn that we have collected the Personal Data of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Data to us, please contact us at [email protected] We will make reasonable efforts to remove such information from our databases.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your personal information to third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the Personal Data; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Campaign Nucleus, LLC
Attn: CA Privacy Rights Request
1512 Broward Blvd Suite 104B
Fort Lauderdale, FL 33301
Our Platform is solely intended for use by individuals located within the United States. Personal Data collected in connection with the use and operation of our Platform is stored and processed in the United States. If you access, use, or otherwise interact with our Platform or otherwise engage with us from outside the United States, your Personal Data will be collected and stored within the United States. Please note, the United States has not been assessed as having adequate privacy laws by some countries and economic regions.
CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Platform after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.
We welcome your questions, comments, and concerns about privacy. Please email us at [email protected] with any questions or feedback you have pertaining to our privacy practices.