Privacy Policy

Last Updated: 07/25/2018

Your privacy is a priority for IDR Marketing Partners LLC d/b/a BrandShare ®, located at 1125 Lancaster Avenue, Berwyn, PA 19312, and its affiliates (“IDRMP”) and we want you to be familiar with how we collect, use, and disclose information relating to you, your computer or your device and that enable your identification (the “Personal Information”). This Privacy Policy describes our practices with information that we (or our service providers) collect through our surveys, websites, apps, and our other network-connected products and services (collectively, the “ Platform”). This Privacy Policy only addresses information collected directly through or from our Platform – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the Platform, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.

When providing Personal Information to us either directly (e.g. by completing a form) or indirectly (e.g. by using the Platform), you will be provided notice of the collection, use and disclosure of your Personal Information as described in this Privacy Policy and you may asked to consent to such collection, use and disclosure. This notice and/or your consent will be relied upon by IDRMP as the justification (legal ground) for collecting and using your Personal Information in accordance with this Privacy Policy. You may, however, revoke this consent or opt-out of such collection, use or disclosure at any time, as further set forth in Section 5 of this Privacy Policy. For the avoidance of doubt, if Section 5 below does not provide choices and options satisfactory to your needs, you always have the option to discontinue using the Platform, including by no longer using our websites or by deleting our applications, products, and services from your devices.

TABLE OF CONTENTS 

1. Information Collection

a. Information You Provide

b. Certain Demographic Information

c. Information Related to Minors

d. Passive Information Collection, Use, and Choices

e. Social Media and Other Third Party Platforms

2. How We Use and Disclose Information

a. Overview of Use and Disclosure

b. Uses and Disclosure to Comply with Laws

c. Interest Based Advertising

3. Third Party Websites and Services

4. Security

5. Choices, Access, and Retention

a. Opting Out of Collection and Disclosure

b. Opting Out of Communications (Emails and Text Messages)

c. Accessing, Correcting, and Updating Your Personal Information

d. Retention of Your Information

e. Data Portability

6. Cross-Border Transfers

7. Contacting Us

8. Updates to this Privacy Policy

1. INFORMATION COLLECTION

a. Information You Provide

Some elements of the Platform may ask you to submit Personal Information in order for you to benefit from the specified features (such as surveys and sample offers) or to participate in a particular activity (such as sweepstakes or other promotions). You may also have the opportunity to submit other data and information about yourself and your surroundings, such as your present location or another location of interest or we may request Personal Information from you when you create an account on a website. You will be informed what information is required to utilize these features of the Platform, and what information is optional.

Certain aspects of the Platform may allow you to post or otherwise submit information, comments, photos, videos, graphics, and other content to the Platform. Upon submission, all such content may become publicly available and may be viewed, read, collected, or used by others, outside of our control, including any geo-location, tags, or other metadata in such submissions.

We may combine the information you submit through the Platform with other information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, including publicly available information sources (such as publicly available social media profiles) as well as our service partners and data licensors, in compliance with applicable laws.

b. Certain Demographic Information

Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements. Where you provide us with such information without request from IDRMP to this end, we reserve the right to erase any such information at our discretion. 

c. Information Related to Minors

The Platform is not intended for persons under the age of 18. We do not knowingly collect personal information online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.

d. Passive Information Collection, Use, and Choices

As you navigate the Platform, certain Personal Information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:

i. Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.

ii. Through your device: If you access the Platform through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Platform.

iii. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Platform, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Platform. More specifically, we use cookies to:

· recognize your computer or device to make your use of the Platform easier, such as to remember your locations of interest and other preferences with the Platform;

· gather statistical information about use of the Platform in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it;

· select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Platform and on other websites, applications, and online services that you use; and

· track consumer responses to online advertisements. To learn more about cookies, please visithttp://www.allaboutcookies.org .

iv. Using Monitoring Tools: The Platform may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies (collectively, “Pixel(s)”), both on certain aspects of the Platform and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Platform usage and response rates, and tracking the activities of users of the Platform and e-mail recipients.

v. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Platform, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Platform usage levels, helping diagnose server problems, and administering the Platform.

vi. Analytic Tools: We also use tools and third party services to collect information about usage of the Platform, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page . Generally speaking, Google Analytics collects information on how often users visit the Platform, what aspects of the Platform they visit when they do so, and what other websites users visited prior to accessing the Platform. The Platform makes use of Google Analytics services for Demographics and Interest Reporting as well as Display Advertising features, including Remarketing, Google Display Network Impression Reporting, and DoubleClick Campaign Manager integration. You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads through the Google Ads Settings page . You may also prevent your data from being collected and used by Google Analytics by opting out through the use of theGoogle Analytics Opt-out Browser Add-on .

vii. Location-Based Features: We may use information about your location to conduct analytics and improve the Platform and to provide certain location-based features and services, as further described in this Privacy Policy and as otherwise described to you at the point of collection. To provide these location-based features, in addition to the information that you voluntarily submit through the Platform, we may also access information about your location using automated means. We generally will collect information about your latitude, longitude, and the date and time when you accessed the Platform. We may disclose location information as described in Section 2(a) of this Policy. Some services on the Platform may continuously track your location information to allow our third party advertising partners to deliver advertisements that are relevant to your current location. Depending on how you access the Platform, your web browser or your mobile device operating system may inform you that the Platform would like to collect your location and request permission to do so. If you allow such access, the Platform will collect your location information. If you decline, you will need to manually enter your location information to utilize certain features of the Platform.

If you are uncomfortable with the idea of your Personal Information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, turning off location-based services, or opting for “Do Not Track” features. See Section 2(c) below for more information on opting out of Interest-Based Advertising. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Platform, you may be required to provide us with certain information. If you do not wish to provide that information through the Platform or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Platform. Changing these settings will not prevent you from seeing advertisements and offers, but those advertisements and offers may not be tailored to your interests and needs.

e. Social Media and Other Third Party Platforms. 

You may engage with our content, such as video, applications, and other offerings, on or through social media services or other third party platforms, such as Facebook, Twitter, and Pinterest. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations, or applications, we may have access to certain information in your profile with that service or platform. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, photos and videos, your list of friends or connections, people you follow and who follows you, and your posts and “likes." For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

2. HOW WE USE AND DISCLOSE INFORMATION

a. Overview of Use and Disclosure

We use Personal Information submitted by you or otherwise collected through the Platform and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Specifically, we may use Personal Information from or about you:

i. to respond to your inquiries and fulfill your requests, such as to send you information or documents that you request and e-mail alerts and to fulfill orders for samples, products, or services;

ii. to send you important information regarding our relationship with you or regarding the Platform, changes to our terms, conditions, and policies, and other administrative information;

iii. to promote our products and services, and the products and services of our third party business partners, including the brands for which we provide samples, products or services, retailers that may distribute samples and other products or services, or other third party brand and retailer partners (“Network”); and

iv. for our business purposes, such as data analysis, audits, developing new products, enhancing the Platform, improving our products and services, identifying Platform usage trends, personalizing your experience on the Platform by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.

We may use any information that does not personally identify you, your computer, or your device, for any purpose.

In order to provide the features and services made available through the Platform and accomplish the goals described in this Privacy Policy or at the point when we collect the information, we disclose your Personal Information as described below and as specifically described elsewhere in this Privacy Policy or at the point we collect information from you:

1. to our affiliates for the purposes described in this Privacy Policy; 

2. to unaffiliated third parties (such as our Network, data brokers, marketing companies, and IT service providers), including by sharing or selling demographic information, location data, advertising and device identifiers, IP address, and usage statistics to our Network and other third parties, some of whom may use it to offer promotions to you for other products and services;

3. to our third party service providers who provide services to us, such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide those services; and

4. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

b. Uses and Disclosures to Comply with Laws

In addition, we use and disclose Personal Information collected through the Platform as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain. As it relates to EU Personal Information, disclosure under subsections (i), (ii), and (iii) will be regulated by European data protection rules.

c. Retargeting.

We and our service providers collect data about your activities that does not personally or directly identify you when you visit our website. This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we collect to serve you more relevant advertisements (referred to as “Retargeting”) and may provide such information to our Network so that they may tailor the advertisements you see on the website and third party websites, to track your response to advertisements, and to measure the effectiveness of advertisements. We collect information about where you saw the ads we serve you and what ads you clicked on. You may opt out by sending an email to [email protected] or writing to IDR Marketing Partners LLC d/b/a BrandShare, Customer Service Department, 1125 Lancaster Avenue, Berwyn, PA 19312.

d. Interest Based Advertising

As described above, we work with a variety of third party business partners, including our Network, advertisers, advertising networks, and advertising and analytics companies that use various technologies to collect data about your use of the Platform, which may include location data. IDRMP and our third party business partners may use the aforementioned technologies to:

i. track how you use the Platform, how you arrived at the Platform, and what you do after you leave the Platform;

ii. record and link your devices, including your personal computer and mobile device (this is called cross-device linking); and

iii. provide you with advertisements relevant to your interests, taking into account your use of the Platform and the other websites and online services that you use. Note that these advertisements may be delivered to you on the Platform, on third party websites and applications, and on a computer or device other than the device from which the information was collected.

This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work with our third party business partners to improve your experiences with the Platform, we do not control their business practices.

Section 1(d) (Passive Information Collection, Use, and Choices) and Section 5(a) (Opting Out of Collection and Disclosure) of this Privacy Policy describe various methods of preventing passive collection and use of your information by our third party business partners. To learn more about Interest Based Advertising and your options with respect to these practices, please visit www.networkadvertising.org/choices ,https://www.datalogix.com/privacy http://www.aboutads.info/choices , and https://choice.microsoft.com/en-US/opt-out .

If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of the following methods:

1. Visit http://www.aboutads.info/choices (for web-based advertising), andhttp://www.aboutads.info/appchoices (for mobile advertising);

2. For mobile advertising, use your phone operating system’s opt-out setting. For instructions on how to “Limit Ad Tracking” on iOS, please visit https://support.apple.com/en-us/HT202074 . For instructions on how to opt out of interest-based ads on Android, please visit https://support.google.com/ads/answer/2662922?hl=en ;

3. Enable the “Do Not Track” feature on your web browser. For instructions on how to do so, please visitwww.allaboutdnt.com; and

4. In accordance with industry self-regulatory principles, you should see an active link in or around IDRMP advertisements that are delivered on other sites using information collected on our Platform, and in or around third-party advertisements that are delivered on our Platform using Interest Based Advertising programs. Clicking on this link will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt-out of these advertising programs.

If you use more than one device, you should renew your opt-out choices on each such device.

3. THIRD PARTY WEBSITES AND SERVICES

The Platform may also contain links to or utilize the features of third party websites and other online services, including our Network and third party payment processors, for your convenience with locating information, products, or services that may be of interest. If you access a third party service from a link on the Platform, any information you disclose to that third party is not subject to this Privacy Policy. In addition, it is possible that these links may be used by third parties or others to collect personal or other information about you.

Some aspects of the Platform may also allow you to interface with other websites (including our Network), social media, and other online services, such as Facebook. We will diligently work to identify these aspects of the Platform to you, for example, by identifying them with the applicable third party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services, as described in more detail in in Section 1(e) of this Policy. If you interface with the Platform through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services.

We are not responsible for the privacy practices of other online services, including other websites (including our Network), advertisers, payment processors, and social media. It is your sole obligation to review and understand the privacy practices and policies of third parties. We do not control the use of cookies or the collection of information by these third parties, nor how they manage such information. The availability of, or inclusion of a link to or interface with, any third party service on the Platform does not imply endorsement of it by us or by our affiliates. Your use of those other sites and services is subject to the privacy policies of those sites and services, and not this Privacy Policy.

4. security

The security of your Personal Information is important to us and we are committed to handling that information carefully. We use reasonable and appropriate organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem.

5. CHOICES, ACCESS, AND RETENTION

a. Opting Out of Collection and Disclosure

The easiest way to stop the collection of Personal Information about you is to discontinue using the Platform, including by no longer participating in surveys, using our websites or by deleting our applications, products, and services from your devices. To uninstall our applications from your devices, such as smartphone applications, tablet applications, connected TV applications, and desktop, you may use the standard uninstall processes as may be available as part of your device or via the application marketplace or network.

In addition, except as necessary to obtain the services or information requested, you may opt out of having your Personal Information (that is within our control) prospectively retained by us or used by us for certain purposes by using emailing us at the email address below. If you registered an account with us, you may also delete your account. You may contact us for any of the foregoing at [email protected] .

Under European data protection rules, you also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects to you or similarly significantly affects you. This implies a right to object to any automated processing, including profiling.

b. Opting Out of Direct Communications (Emails and Text Messages)

We want to communicate with you only if you want to hear from us. To that end, we give you choices regarding our use and disclosure of your Personal Information for purposes of sending communications to you, such as by emails or text messages or through push notifications. You may opt out from:

i. Receiving Direct Marketing Communications From Us: Where your Personal Information are processed by us or upon our instructions for direct marketing purposes, you have the right to object at any time to such processing, including any profiling conducted for that purpose. If you no longer want to receive direct marketing communications from us on a going-forward basis, you may opt out of receiving them by contacting us at [email protected]. In your response to us, please provide your name, identify the forms of marketing communications that you no longer wish to receive, and include the addresses or telephone numbers to which they are sent. For example, if you no longer wish to receive marketing e-mails or direct mail from us, tell us that, and provide your name and e-mail or postal address. In addition, you may opt out of receiving marketing e-mails and text messages from us by following the unsubscribe instructions provided in any such messages.

ii. Sharing of Your Personal Information for Direct Marketing: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates, our Network and/or other third party partners for their direct marketing purposes (such as direct communications by email, text message, and mailings directed to you), you may opt out of this sharing by contacting us at [email protected]. In your response to us, please state that we should no longer share your Personal Information with our affiliates and/or third party partners for their direct marketing purposes, and include your name and e-mail address.

We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of our affiliates or third party partners with which we have already shared your information (i.e., as of the date that we implement your opt-out request) but we will take all reasonable steps, including technical measures, to inform third parties which are processing your Personal Information that you have opted out as described above. Please also note that if you opt out of receiving direct marketing messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to available upgrades, billing and payment information, outstanding balance on your account, and other emails relating to your account and/or your use of the Platform).

c. Accessing, Correcting, and Updating Your Personal Information

i. For US residents: At your request, we will provide you with a summary of the Personal Information that we maintain in connection with your account with the Platform that has been voluntarily provided by you through email, registration forms, or other contact forms. You may contact us for any of the foregoing at [email protected]. Upon your request and to the extent required by applicable law, we will update or correct that information. We will try to comply with your request as soon as reasonably practicable. You may also visit the Platform to update your online profile or change your password.

Additionally, California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to [email protected] .

ii. For users accessing the Platform from the European Union: You have the right to request that we confirm what Personal Information we collect or hold about you, and to ask us to correct or update such Personal Information. You may contact us for any of the foregoing at [email protected]. You may also visit the Platform to update your online profile or change your password. To help protect your privacy and provide security, we may take reasonable steps to verify your identity in the context of the above requests, e.g. by asking you to provide a copy of your ID card or password.

d. Retention of your Personal Information

i. For US residents: We retain your Personal Information for as long as you have a registered account with us or as long as needed to provide you services through the Platform. If you request that we delete or restrict certain directly identifying Personal Information about you that, was collected by us through your account with the Platform of through email, registration forms, or other contact forms, we will comply with your request, but please note that we may nevertheless retain and use such records for a period of time; for example, to follow-up on a request, resolve a dispute, in order to comply with applicable federal, state, or local law, or for other similar reasons. In addition, some Personal Information may also continue to be stored on back-up files for financial, legal, or technical reasons. Note that we cannot erase or restrict use of your Personal Information that is controlled by a third party, including any of your Personal Information that was disclosed by us to a third party prior to your request.

ii. For users accessing the Platform from the European Union: We retain your Personal Information for as long as you have a registered account with us or as long as needed to provide you services through the Platform. You have the right to request (i) erasure of your Personal Information (“right to be forgotten”) or (ii) restriction of the processing of your Personal Information for certain purposes only (please refer to the first page of this policy regarding how to exercise your rights). If you request that we delete or restrict certain Personal Information about you that is maintained by us, we will comply with your request, but please note that we may nevertheless retain and use such records for a period of time; for example, to follow-up on a request, resolve a dispute, in order to comply with applicable federal, state, or local law, or for other similar reasons. In addition, some Personal Information may also continue to be stored on back-up files for financial, legal, or technical reasons. Note that we cannot erase or restrict use of your Personal Information that is controlled by a third party, including any of your Personal Information that was legally disclosed by us to a third party prior to your request.

iii. Cookies installed on your system will be stored indefinitely.

e. Data Portability

For users accessing the Platform from the European Union: You have the right to obtain your Personal Information in a machine readable format and to ask for such data to be transferred directly by IDRMP to another third party. Please refer to the first page of this policy regarding how to exercise your rights.

6. CROSS-BORDER TRANSFERS

The Platform is controlled and operated from within the United States. Notwithstanding the foregoing, your Personal Information may be stored and processed in any country where we have facilities or service providers. By using the Platform or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. We make no representation that the Platform is appropriate or available for use outside the United States, or that access and use of the Platform in accordance with this Privacy Policy complies with the laws of your jurisdiction. Those who choose to access the Platform from outside the United States do so on their own will and are fully responsible for compliance with applicable laws.

To enable IDRMP to carry out the above cross-border transfers of your Personal Information, IDRMP will request your explicit consent with the above and rely on such consent as the legal justification for these transfers.

7. CONTACTING US

If you have any questions concerning this Privacy Policy or wish to exercise your rights as described in this Policy, please email us at: [email protected]. You can also reach us through https://www.brandshare.us/contact/ or at: Customer Service Department, 1125 Lancaster Avenue, Berwyn, PA 19312 USA.

8. UPDATES TO THIS PRIVACY POLICY

We reserve the right to change or amend this Privacy Policy from time to time. We will inform you about any changes or amendments to this Policy ahead of time prior to such changes taking effect (e.g. by sending you an email or by posting a note when you enter the Platform, recommending you to take look at the “LAST UPDATED” legend at the top of this page to see the revised Privacy Policy).

Where the changes relate to how we collect, use and disclose your Personal Information, your consent will be requested in that respect. If you do not accept the changes or amendments, we continue processing your Personal Information on the basis of the last accepted policy version, but you may be unable to obtain certain content, features, services, products, or benefits of the Platform.