Privacy Policy

Last updated: May 8, 2020

Proffiliates, Inc. (“Proffiliates”) and its wholly owned subsidiaries (collectively, “Company”, “us”, or “we”) respect and value your privacy rights. This Privacy Policy describes the types of information we co llect about you through (the “Site”); how we secure that information; how we use that information; and the choices you have regarding the collection and use of your information. By usin g and/or signing up for any service provided through the Site, you must be at least 18 years old and cons ent to this Privacy Policy.

This Site is intended to be used in the United States only. The Site is controlled and operated from the United States, and is not intended to subject Company to the laws or jurisdiction of other country, excep t for the United States. This Privacy Policy is provided in accordance with and subject to applicable Uni ted States law. You may be located in a country that has laws which are more restrictive about the colle ction and use of your personal information. However, by using our Site, you agree to waive the more restr ictive laws and agree to be governed by the laws of the United States. Further, if you decide to continue to access the Site from a location outside of the United States, you hereby agree that your use of the S ite is subject to this Privacy Policy and that your personal information will be transferred or processed in the United States. Your information may be collected, accessed, processed and stored in the United St ates as well as in any other country where we, our affiliates, service providers, or our third party part ners maintain facilities. By using the Site, you consent to the transfer of such information to countries outside or your country of residence, which may have different data protection rules than those of your country.

Information We Collect and Retain

We collect and retain information which you voluntarily provide to us through the Site, which may include your name, email address, and any other information which you provide to us through your registration on the Site and in connection with your subscription to receive our newsletter and alerts, unsubscribing fr om our mailing list, or by contacting us through the Site.

We also automatically collect and retain information based on your visit to the Site and interaction with the Site, including your internet protocol (IP) address, browser type and version, operating system, sof tware, and platform, geographic location, time zone setting, date, time, and length of your visit, referr ing and exit domain names and websites, screen resolutions, color capabilities, browser plug-ins, languag e settings, cookie preferences, search engine keywords, JavaScript enablement, and clickstream data. Whil e an IP address does not identify an individual by name, it may, with the cooperation of the internet ser vice provider, be used to locate and identify an individual using the web. An IP address can also reveal what geographic area an individual is connecting from, or which ISP they are using. Company may collect o r receive information using the following directly through the Site, and through third parties:

  • Cookies. “Cookies” are a feature in your browser software. If enabled, Company may write cookies that store small amounts of data on your computer about your visit to any of the pages of our Site. We predom inately use “session” cookies, which are not permanently stored on the consumer’s hard drive. Session coo kies expire after two hours of inactivity or when the consumer closes the consumer’s browser. A large amo unt of data is processed by our system and transferred through each page of the search or registration. T his information includes all information input on a registration page or questionnaire completed as part of the registration process as well as demographic information that is not unique to the consumer. “Sessi on” cookies allow us to keep track of this data until the consumer has completed its search or registrati on. Cookies assist us in tracking which of our features appeal the most to you and what content you may h ave viewed on past visits. When you visit our Site again, cookies can enable us to customize our content according to your preferences. We may use cookies to keep track of the number of return visits to our Sit e; accumulate and report aggregate, statistical information on Site usage; deliver specific content to yo u based on your interests or past viewing history; and track, monitor and target the interests of consume rs for advertising and delivery purposes. We use third party tracking technologies and allow our third pa rty advertising partners, including advertising agencies, advertising networks, and other companies who p lace advertisements and links on the Site, to utilize their cookies and web beacons on our Site. Such thi rd party advertising partners may use information collected for behavioral data analysis, statistical ana lysis or for the purposes of target advertising. You may read more about cookies at http://cookiecentral. com. You can disable cookies, although the Site may not function properly for you. Your browser preferenc es can be modified to accept or reject all cookies, or request a notification when a cookie is set. In or der to use all of the features and functionality of the Site, you need to accept cookies.
  • Web Beacons. Web beacons (also known as “clear gifs”, “one-pixel gifs”, “web bugs”, “Internet tags”, or “pixel tags”) are code that can be used to display an image on a web page, but can also be used to tra nsfer your unique user identification to a database and associate you with previously acquired informatio n. Web beacons collect only a limited set of information including a cookie number, time and date of page view and a description of the page on which the web beacon resides. Web beacons allow us to collect cert ain information about your Site visit and to compile aggregated statistics about Site usage. In addition to using web beacons on the Site, Company also uses web beacons in its email communications, which help u s track whether a user opens and/or clicks on the emails and the links contained within. Company shares s uch information with third parties so that they can understand the kinds of visitors to the Site, how tho se visitors use the Site, and the effectiveness of their advertisements. Because web beacons are the same as any other content request, the consumer cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your web browser.
  • JavaScript. We may also use JavaScript within certain advertisements. JavaScript is a computer langua ge that enhances the functionality of websites, particularly in respect to pictures. We use such data to analyze and improve the Site’s functions. You may deactivate JavaScript via your consumer’s browser setti ngs or activate it the same way. If you disable JavaScript, the functionality of the Site may be affected .
Apart from use of the above technologies on our Site, we automatically collect information when an indivi dual opens our newsletter, or one of our emails, through the use of cookies, web beacons, and/or JavaScri pt.

In addition to our collection of information through the Site and our email communications, we also may c ollect and retain information received from third parties, such as advertising companies and networks and consumer data resellers/brokers, by leasing such information for our commercial use. We require represen tations and warranties that such data was collected and transferred to Company consistent with the third party’s posted privacy policy. We receive the following consumer information from such third parties: fir st and last name, physical address, email address, phone number, fax number, IP address and any other inf ormation the consumer provided to the data owner at the time of registration at the data owner’s website.

No Information Collected from Children

We will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that inf ormation will be immediately deleted from our database. Because we do not collect such information, we ha ve no such information to use or to disclose to third parties. If you are aware that your minor child und er the age of 13 has provided us with personal information, please contact us.

How Information is Used and Shared

Providing the Site, Services and/or Products: We use the information we gather on the Site to respond to any inquiries, operate and improve our Site, improve and create a positive user experience, and deliver t he products or services advertised on our Site. Our services include the display of personalized products or services, content, and advertising relating to the consumer’s experience and interests. The informati on we gather on this Site may be shared with our affiliated companies that are directly or indirectly con trolled by us, or under common control. We use the information we gather on the Site to provide individua ls with the products or services requested. This may include passing the individual’s information on to a third party with whom we have a contract to provide such products or services. Although our contractual arrangement limits how such third party can use the consumer’s information, we do not control the privacy practices of this third party. If the consumer has any questions or wish to remove the consumer’s inform ation from the third party’s database, the consumer will need to contact that party directly. We disclose information to companies and individuals we employ to perform technical functions on our behalf, includi ng hosting of the Site, data analysis, marketing assistance, and providing customer service. These compan ies and individuals may not share that information with any other third party or use that data for any ot her purpose.

Service of Marketing Material. We also use the information collected to send relevant marketing content t o consumers. We may also use information collected from web technology to supplement the information you provide directly to us. The combination of web technology information with the information directly provi ded to us enables Company to offer tailored and relevant marketing material via email. We may also use in formation to contact persons about Site updates, conduct surveys, or informational and service-related co mmunications, including important security updates.

Third Party Products and Services: We may disclose such information to third parties for marketing purpos es, including to provide information about the opportunities, products or services of third parties, and in order to effect or carry out any transaction that you have requested from us or that is necessary to c omplete our contractual obligations to you. We use the data and data logs we have about the consumer, inc luding interests and preferences the consumer has expressed, to determine whether the consumer might be i nterested in the opportunities, products or services of a particular third party. This type of marketing may be in the form of email offers by third parties. We also share aggregated anonymous information about individuals using our Site with third parties so that they can understand the kinds of visitors to the S ite and how those visitors use the Sites. This includes demographic information and behavioral informatio n. We may also share information with third parties who provide services to us, including, but are not li mited to: email service providers, providers of direct marketing services and applications, including loo kup and reference, and data enhancement, suppression and validation services (“Service Providers”). Our S ervice Providers undertake services for marketing efforts on behalf of third party advertisers who have r etained Company to provide for such marketing. However, the Service Providers are under written contract not use this information for any other marketing purposes including marketing their own companies and are strictly prohibited from sharing this information with any third party. These Service Providers are reta ined to enable Company to deliver marketing materials to consumers, verify and update information about t he consumer, allow the consumer to unsubscribe from receiving further emails, and better tailor relevant advertising to the consumer.

Complying with Legal Process. We will use or disclose your personal information in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise our legal rights or defe nd against legal claims or in the event of a breach in an agreement with us. We will use and disclose you r personal information in the event that we believe that a user of this Site will harm the property or ri ghts of us, our owners, or our other customers. Finally, we will use or disclose personal information if it believes it is necessary to investigate, prevent, or take action regarding illegal activities, suspect ed fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions.

Merger or Sale of Company. In the event that we sell, merge, or otherwise reorganize our business, we res erve the right to transfer and disclose your information to the purchaser or investors, but will require such person or entity to govern the collection, storage and use of such information by the same privacy p olicy that existed prior to any such business change unless and until you consent to the new privacy poli cy. In addition, in the event we become the subject of an insolvency proceeding, whether voluntary or inv oluntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or o therwise dispose of such information in a transaction approved by the court. Again, in each of these situ ations, the recipients of the consumer’s data may potentially be located in any country in the world.

Choices Regarding Information Use and Sharing

Unsubscribing from Emails: Unsubscribe requests are either processed on an advertiser specific basis or o n a Company specific basis depending on the selection the recipient makes. All commercial emails sent by Company contain an unsubscribe hyperlink that allows the recipient to unsubscribe from receiving commerci al emails from the advertiser whose marketing material appears in the commercial email by clicking the hy perlink provided and following the instructions provided by such advertiser. Advertisers are required by law and our contract to process all unsubscribe requests promptly. Unsubscribing from one advertiser will not prevent the recipient from receiving other advertisers’ emails.

In addition, a recipient may unsubscribe from receiving any commercial emails from Company. All commercia l emails sent by Company contain a second hyperlink that allows the recipient to unsubscribe from all lis ts managed by Company by clicking the hyperlink provided and following the instructions provided by Compa ny. Upon selecting the Company unsubscribe link, the consumer’s request will be complied with through our own database, or as may be applicable, forwarded to the data owner. There is no legal requirement that d ata owner remove consumers from their database and as such we cannot guarantee that the Company’s unsubsc ribe notice will be honored in every instance.

We have no control over any information that third parties, including advertising networks and advertiser s, may obtain, store or use. We encourage you to visit their websites to review and read their privacy po licies and opt-out practices that govern their usage.

Cookies, web beacons, and JavaScript: You may also turn off cookies through your web browser. However, th is may affect your use of our Site as well as other’s sites. There are many ways to eliminate or block co okies from your browser. Please see http://cookiecentral.com for more information. Web beacons can also b e rendered ineffective by either opting out of cookies or changing the cookie setup in your web browser. You may deactivate JavaScript via your consumer’s browser settings, however the functionality of the Site may be affected.

If you would like to be removed from our database, or no longer wish to receive our email communications or newsletters, please email us at unsubscribe@proffiliates.com. If you wish to review the information re lated to you collected through the Site, please provide the request in writing to general@proffiliates.co m. We reserve the right to confirm the identity and association of the person requesting such information prior to disclosure. When you request us to delete your personal information, it will be deleted, but we will retain logs, demographic and statistical information about you and keep an archival copy of your in formation in an anonymous form. To the extent that your personal information was previously accessed by o thers or transferred to others using our Site, we are unable to delete the information from their systems .

Third Party Use of Information

As noted above, we use third party tracking technologies and allow our third party advertising partners t o utilize their cookies and web beacons on our Site. Such third party advertising partners may use inform ation collected for behavioral data analysis, statistical analysis, or for the purposes of target adverti sing. We do not control the use of such technology and have no responsibility for the use of such technol ogy to gather information about the consumer.

To the extent that you agree to receive push notifications from the Site, we rely on third-party service providers to deliver such push notifications.

Our Site and email messages sometimes contain hypertext links to the websites of third parties. We are no t responsible for the privacy practices or the content of such other websites. Such links are provided fo r the consumer’s convenience and reference only. We do not operate or control in any respect any informat ion, software, products or services available on such third party websites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organ ization. This Privacy Policy only addresses our use and disclosure of information which we collect from y ou. The third party websites which are accessible through our Site, and companies to whom your informatio n is transferred, have their own privacy policies and data collection, use and disclosure practices. Plea se consult each third party website's privacy policy.

California Residents – Your Privacy Rights

If you are a California resident, your use of the Site is subject to the California Consumer Privacy Act (“CCPA”). Additional information is available here. If you would like to learn how your personal information is shared with third parties, what categories of personal informatio n we have shared with third parties in the preceding twelve (12) months, as well as the names and address es of those third parties, please contact us via email at privacy@proffiliates.com, or by mail at 50 Cali fornia Street, Suite 1500 San Francisco, CA 94111. If you would like to opt-out from the disclosure of yo ur personal information to any third party for marketing purposes, please contact us via email at privacy @proffiliates.com, or by mail at 50 California Street, Suite 1500 San Francisco, CA 94111.

In addition, under California’s Shine the Light law (California Civil Code Section 1789.83), California r esidents have the right to request, once a year, information on the types of personal information we have shared with third parties for their direct marketing purposes during the immediately preceding calendar year; and the names and addresses of third parties with whom we have shared the personal information. You have agreed to allow us to share information with third parties for their direct marketing purposes unti l you request to opt-out of such sharing. California customers may request further information about our compliance with this law by contacting us via email at ccparequests@proffiliatesinc.com, or by mail at 50 California Street, Suite 1500 San Francisco, CA 94111. Within thirty days of receiving such a request, w e will provide a list of the categories of personal information disclosed to third parties for third-part y direct marketing purposes during the immediately preceding calendar year, along with the names and addr esses of these third parties. This request may be made no more than once per calendar year. We reserve ou r right not to respond to requests that are not submitted in accordance with this section.

Security

We endeavor to safeguard and protect your information. We use redundant and robust servers to host intern al data, which are also protected by high performance firewalls housed in one of the premium collocation services in California. Our web front end and application systems are user and password protected to prev ent access from unauthorized users. The servers in which we store personal information are kept in a secu re physical environment. Company has security measures in place to protect against the loss, misuse, and alteration of personal information under our control. In addition, the Company currently uses Secure Sock et Layer Software (“SSL”) to protect data and to secure any transactions. SSL encrypts information transm itted over the Internet. Please be advised that, although Company takes reasonable technological precauti ons to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. The refore, Company cannot and does not warrant that your information will be absolutely secure. Any transmis sion of data at or through our Site is at your own risk. However, access to your information is strictly limited, and not accessible to the public.

Changes to Privacy Policy

We reserve the right to modify or change our Privacy Policy at any time for any reason. The updated Priva cy Policy will be effective upon posting without further notice. Your use of the Site after such modifica tions will constitute your acknowledgment of the modified Privacy Policy; and agreement to abide and be b ound by the modified Privacy Policy.

How to Contact Us

You may contact us about our privacy practices at:

Proffiliates, Inc.
50 California Street, Suite 1500 San Francisco, CA 94111
E: general@proffiliates.com
T: 415.647.7601

Do You Need Extra Help?

If you have a disability which interferes with your ability to access this policy, we can make accommodat ions to present the policy in an alternative format to assist you. If you would like to receive this Priv acy Policy in another format that is accessible to your needs (for example: audio, large print, etc.) ple ase contact us.