Website Privacy Policy

MONETATE, INC. WEBSITE PRIVACY POLICY

Last Updated June 2017


We at Monetate, Inc. (“Monetate,” “we,” “us,” or “our”) have created this privacy policy (this “Website Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Website Privacy Policy relates to the Monetate’s information collection and use practices in connection with our website located at http://monetate.com (the “Website”). 

Please note that our privacy practices governing our proprietary marketing optimization technology is governed by our Platform Privacy Policy.

The Information We Collect

In the course of operating the Website, Monetate will collect the following types of information.

  • Personal Information. When you request information about our products and services or sign up to receive information from us, you may be required to provide us with personal information about yourself, such as your name, company, title, address, e-mail address, and phone number. We do not collect any personal information from you when you access and use the Website unless you provide such information voluntarily. All information we collect and/or receive under this section is collectively called “Personal Information.”
  • Other Information. In addition to the Personal Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
    • From Your Activity. Information that we or our technology providers may automatically collect when you visit, access, and/or use the Website, such as your IP address, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and operating system.
    • From Cookies and JavaScript Tags. We collect information using “cookie” technology and JavaScript tags. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website. If you do not want us to place a cookie on your hard drive, you may use your browser’s preferences to turn that feature off on your computer. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly. We use JavaScript tags to trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist) and to help us tailor and optimize our Website and provide you relevant Monetate advertisements outside of our Website.
How We Use and Share the Information

We use the Personal Information and the Other Information (collectively, the “Information”) to administer our rewards and promotional programs; to improve our Website and services to you; to solicit your feedback; and to inform you about our products and services.

We may also use and/or share Information as described below.

  • We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
  • In an ongoing effort to better understand visitors to our Website and our products and services, we may analyze the Other Information in aggregate form in order to operate, maintain, manage, and improve the Website and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
  • In order to provide our services and administer our rewards and promotional programs, we may share your Personal Information and Other Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
  • If you have opted out of our ability to use your e-mail address, as set forth on the Website, we may share your decision to opt out with third parties to effectuate that decision.
  • To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Monetate or others.
Accessing and Modifying Information and Communication Preferences

Visitors who have provided Personal Information to us may access, remove, review, and/or make changes to the same by following the instructions found on the Website. In addition, you may manage your receipt of marketing and communications by clicking on the “unsubscribe” link located on the bottom of any Monetate marketing e-mail or by following the instructions found on the Website. We will process such requests in a timely manner. 

How We Protect the Information

We take all necessary steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction as required by applicable law or the EU-US or Swiss-US Privacy Shield Principles. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet.  In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents/EU-US and Swiss-US Privacy Shield

Monetate complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union and Switzerland to the United States, respectively. Monetate has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. Monetate subjects all Personal Information received from the European Union or Switzerland in reliance on the EU-US or Swiss-US Privacy Shield, as applicable, to these Principles. If there is any conflict between the terms in this Platform Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield Program, and to view Monetate’s certification page, please visit https://www.privacyshield.gov.  The list of the self-certified organizations can be found at https://www.privacyshield.gov/list.

Monetate will process all Personal Information received under the EU-US or Swiss-US Privacy Shield only in ways that are compatible with the purpose for which such information was collected, or for purposes authorized by you later on. We will provide you with the possibility to opt out in case we want to (i) disclose your Personal Information to a third party that is not acting as an agent to perform tasks on our behalf and under our instructions or (ii) use your Personal Information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Monetate commits to investigate and attempt to resolve complaints about your privacy and our collection or use of your Personal Information within 45 days of receiving your complaint.  European Union or Swiss individuals with inquiries or complaints regarding this Platform Privacy Policy should first contact Monetate at privacy@monetate.com.

Monetate has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit independent dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.  If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint (free of charge).  

Under certain conditions you have the possibility to invoke binding arbitration in order to determine whether Monetate has violated its obligations under the EU-US or Swiss-US Privacy Shield Principles as to you, and whether such any such violation remains fully or partially unremedied. You must take following steps prior to initiating an arbitration claim: (1) raise the claimed violation directly with Monetate and afford us an opportunity to resolve the issue within 45 days of receiving your complaint; (2) make use of the independent dispute resolution mechanism, which is at no cost to you; and (3) raise the issue through your Data Protection Authority to the Department of Commerce and afford the Department of Commerce an opportunity to use best efforts to resolve the issue, at no cost to for you. Please check https://www.privacyshield.gov and Annex I (Binding Arbitration) of the EU-US Privacy Shield Framework for further information.

You may have the right under the EU-US and Swiss-US Privacy Shield to access the Personal Information that we hold about you and to request that we correct, amend or delete it if it is inaccurate or processed in violation of the EU-US or Swiss-US Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. We will respond to access requests within a reasonable time period, in a reasonable manner and readily intelligible form. We may charge a fee that is not excessive to cover the costs for providing access. We may also set reasonable limits on the number of times within a given period in which access requests from a particular individual will be met. We may request specific information from you to confirm your identity.   

Please note that Monetate may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

As set out above, Monetate may transfer Personal Information to our third-party agents who perform functions on our behalf. Where required by the EU-US and Swiss-US Privacy Shields, we will enter into written agreements with those third-party agents requiring them to provide the same level of protection each of the EU-US and Swiss-US Privacy Shield requires and limiting their use of the Personal Information to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents process Personal Information received in reliance of the EU-US and Swiss-US Privacy Shield in accordance with our EU-US and Swiss-US Privacy Shield obligations and to stop and remediate any unauthorized processing. We shall remain liable under each of the EU-US and Swiss-US Privacy Shield Principles if our agent processes Personal Information in a manner inconsistent with the EU-US and Swiss-US Privacy Shield Principles, as applicable, unless we can prove that we are not responsible for the event giving rise to the damage.

Under the conditions set out above, we may also transfer Personal Information received under each of the EU-US and Swiss-US Privacy Shield to third-party data controllers. These third parties do not act as agents and are not performing functions on our behalf. We will only provide such Personal Information to third-party data controllers where you have not opted-out of such disclosures. Where required by the EU-US or Swiss-US Privacy Shield, we will enter into written contracts with such third-party data controllers requiring them to provide the same level of protection the EU-US or Swiss-US Privacy Shield requires. We also limit their use of such Personal Information so that it is consistent with any consent you have provided and with the notices you have received.  

Monetate is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Website. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Website Privacy Policy by instructing their children never to provide Personal Information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents

Monetate does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

External Websites

The Website may contain links to third-party websites. Monetate has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Website Privacy Policy

This Website Privacy Policy is effective as of the date stated at the top of this Website Privacy Policy. We may change this Website Privacy Policy from time to time. By accessing and/or using the Website after we make any such changes to this Website Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Website Privacy Policy in effect at the time we collect the Information. Please refer back to this Website Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Website Privacy Policy, please contact Monetate via e-mail at privacy@monetate.com with “PRIVACY POLICY” in the subject line.

 

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