INTERACTIVE OFFERS PRIVACY NOTICE

Effective date of this Privacy Policy: 20th July 2019
Introduction

Welcome to INTERACTIVE OFFERS’s privacy notice.

INTERACTIVE OFFERS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we use and look after your personal data when you visit our website and when we provide our services to you (regardless of where you visit from) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how INTERACTIVE OFFERS collects and processes, clients and users personal data through your use of the INTERACTIVE OFFERS websites and INTERACTIVE OFFERS network of publisher sites, including any data you may provide through this website when you sign up to our newsletter or request information about other products and services from INTERACTIVE OFFERS. It also describes how in the course of providing our services to our advertising clients we collect and use your personal data for analytical purposes and in order to deliver personalized advertisements for products or content you might be interested in. This website is not intended for children under the age of thirteen (13) and we do not knowingly collect data relating to children. However, if children who are under thirteen (13) provide personal information to us, their parents or legal guardian can request us to delete this information from our records by sending us an email at support@interactiveoffers.com.  It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

INTERACTIVE OFFERS LLC, is the controller and responsible for your personal data (collectively referred to as "INTERACTIVE OFFERS", "we", "us" or "our" in this privacy notice).

INTERACTIVE OFFERS LLC is the controller and responsible for this website.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact us at: support@interactiveoffers.com

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 20th July 2019 and previous versions can be obtained by contacting us at: support@interactiveoffers.com

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites or network of publisher sites, we encourage you to read the privacy notice of every website you visit. The data we collect about you

If you do not fill in one of our forms, we do not know who you are, your address, your date of birth, your email address or your phone number.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you (as a user, advertiser or publisher) which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details. (This only applies to our advertisers, publishers and X)

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our services.

Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, network of publisher sites, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website, content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Automated technologies or interactions. As you interact with our website or network of publisher sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. We record  your browsing behavior when you visit websites on which our ads are displayed including which pages are visited. This can be used to target you with personalized advertising and for analytics purposes.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

How we use your personal data

Most commonly, we will use your personal data in the following circumstances:

INTERACTIVE OFFERS does not cookie EEA users (and other users from countries were GDPR applies) for the purpose of behavioral targeting. INTERACTIVE OFFERS will serve ads to EEA users contextually and therefore will not require users’ consent for targeting purposes.

Apart from as stated above, generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email and for behavioral targeting. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

  1. Marketing / Targeting
    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
  2. Promotional offers from us
    For users outside the EEA, We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). In most cases we will show you recommendations based on the context of the page and not on your personal data profile.
    You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered your details in one of our form
  3. Third-party marketing
    INTERACTIVE OFFERS may also use third parties to serve ads.These third parties may collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Website (but not personal information such as your name, address, email address or telephone number). They do this using their own cookies, clear gifs or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other sites tracked by these third parties.  This policy does not apply to, and we are not responsible for, cookies or clear gifs in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology.
  4. Opting out
    You can opt-out from marketing messages at any time by contacting us.You can also opt-out from our cookies for interest based ads by opting out on this page - https://ionlytic.com/adChoices.php
    Tracking mechanisms operate at the device and browser level, so if you would like to opt-out across all devices, you will need to do so on each device and browser individually.
  5. Cookie Policy
    To enhance your online experience we use "cookies." Cookies are text files placed by the Website in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personal information. However, once you choose to furnish the Website with personal information (such as signing up to receive one of the offers made by our third party advertising partners), this information may be linked to the data stored in the cookie. We use cookies to understand Internet usage, enhance the performance of the Website, activate special web features and security mechanisms. In addition, we may use cookies to offer you products, programs or services which may be part of client retargeting campaigns.
    You always have the option of setting your browser to warn you when a cookie is being accessed on your computer, to delete cookies that are currently on your computer or to decline cookies altogether. However, to take full advantage of the Website and its features, your browser will need to accept cookies.
    Web beacons (also known as clear gifs) are small, invisible graphic images that may be used on the Website and in e-mails to collect certain information about your use of and activity with the Website and emails. If we combine cookies or clear gifs with or link them to any of the personally identifying information, we would treat this information in the same way we treat other personal information.
    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
  6. Change of purpose
    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  7. Disclosures of your personal data
    We may share data or aggregated data with affiliates, subsidiaries or service providers for the purpose of delivering our services.
    Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
    We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
  8. International transfers
    We share your personal data within INTERACTIVE OFFERS LLC. This will involve transferring your data outside the European Economic Area (EEA).
    Some of our External Third Parties in North America and APAC are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
  9. Data security
    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
  10. Data retention
    How long will you use my personal data for?
    The retention period will depend on the type of data concerned.
    Data in our DMP is retained for 12 months for users outside the US, Canada, Singapore, Hong Kong, India, then deleted.
    Data relating to contracts might be kept for 7 years (ie the 6 years within which a legal claim could be brought under the contract plus one year for the claim to be dealt with).
    Financial data (eg payments) are kept for 12 years.
  11. Your legal rights
    You have the right to make a complaint at any time to the data protection authority about data protection issues. To know more, please contact your local data protection authority on this link.
    We would, however, appreciate the chance to deal with your concerns before you approach your local authority so please contact us in the first instance.
    You have certain rights regarding your personal data, please see here.
    Where we rely on our legitimate interests to obtain and use your personal data then you have the right to object if you believe your fundamental rights and freedoms outweigh our legitimate interests.
    Where processing is carried out based upon your consent, you have the right to withdraw that consent.
    Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular data we hold on you.
    You should note that if you exercise certain of these rights we may be unable to continue to provide some or all of our services to you (for example where the personal data is required by us to comply with a statutory requirement, or is necessary in order for us to perform our contract with you).
    Please contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate.
    You may also exercise a right to complain to your Supervisory Authority. Please contact the Data Protection Officer if you wish to exercise any of your rights.
    If you wish to exercise any of your rights, please contact us
  12. No fee usually required
    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
  13. What we may need from you
    We may need to request specific information from you to help us confirm your identity such as your driving licence or passport and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  14. Time limit to respond
    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
  15. Glossary
    LAWFUL BASIS
    Network of Publisher Sites: INTERACTIVE OFFERS works with many publisher sites.
    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  16. THIRD PARTIES
    Internal Third Parties within INTERACTIVE OFFERS acting as joint controllers or processors and who are based in the US, Portugal, Australia and provide IT and system administration services and undertake group reporting.
  17. External Third Parties
    Service providers acting as processors based inside or outside the EEA.
    Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based US, Portugal, Australia who provide consultancy, banking, legal, insurance and accounting services.
    HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain
  18. Changes to This Privacy Policy
    This Privacy Policy is current as of the Effective Date set above.
    We may change this Privacy Policy from time to time, so please make sure to check it on a regular basis.