Privacy Policy

This ValidClick, Inc. Privacy Policy describes the practices concerning the information collected by ValidClick, Inc. and its affiliates (“ValidClick Apps”, “we”, “us” and “our”) through the use of the (i) website and browser add-on (the “ValidClick Apps Product”) and (ii) our “Search Application” made available by means of a search box on an ValidClick Apps Product (collectively the ValidClick Apps Product and Search Application are hereinafter referred to as the “ValidClick Apps Services”.

1. INFORMATION WE COLLECT

We collect information from you in a variety of different ways, including the information you provide when you communicate with us and information we collect when you use the ValidClick Apps Services. This may include information that identifies you but also includes anonymous information, such as the number of your page views, link clicks, and usage logs.

Categories of Information:

Identifiers  Name, telephone number, email address, unique online identifier (UUID) or IP address. 

Commercial information Records of our products or services obtained, or considered, or other histories or tendencies.

Internet or other similar network activity Browsing history, search history, information on your interaction with the Search Application, or advertisements we or our partners serve.

Geolocation data General location or movement data which may be inferred from your IP address.

Sources of Information

A.    Information You Provide to Us

We may collect and store any information you choose to provide when using the ValidClick Apps Services. This may include information such as: Your name and/or email address (in the provision of customer support/your data rights request).

B.    Automatically Captured Information

We automatically collect information from your computer when you use the ValidClick Apps Services. This allows us to assess how you have used the ValidClick Apps Services, the device you have used them on and helps us to analyze how we can optimize the ValicClick Apps Services for you. This information may include:

·      Internet Protocol (IP) address.

·      UUID.

·      Browser type/version and language and other browser-related information and a timestamp.

·      Features usage data that includes your interactions with the features provided by the ValidClick Apps Services.

·      Information about how you use the Search Applications such as the keyword query, search query text, search results clicked, ValidClick Apps hosted pages viewed and search history. For example, when you enter a search query using the Search Application, we receive the query text and process it, together with the above data, to return a search results page to you.

·      Cookies and Other Technologies: the ValidClick Apps Product does not install Cookies. However, in order to access and use features of the Search Application services, we or our technology partners may use cookies and similar technologies (such as local stored objects) in connection with the sites to collect and store information when you interact with the features of the Search Application. Certain information such as the content of any of our undeleted cookies, including a non-personal identifier and the referring website address. We may use standard Internet technology, such as web beacons, and other similar technologies, to track your use of the Search Application. 

C.    Third Parties 

Third Parties: We may allow third parties, including our authorized service providers, affiliates, advertising companies, and ad networks, to display advertisements or place ad tags or beacons on the ValidClick Apps Services on the computer you use to access our ValidClick Apps Services and to recognize that device to across different websites for the purpose of serving advertising relevant to your interests. We do not control third parties’ collection or use of information to serve interest-based advertising.

We or these third parties may collect the following information:

·      Geographic location derived from your IP address on your visits to the ValidClick Apps Services and non-affiliated websites and applications;

·      Data about your use of or visits to the ValidClick Apps Services and non-affiliated websites and applications;

·      Data on your interaction with the advertisement displayed on third party websites and applications; 

·      Interest and usage data (the pages you view and links you click on); and

·      We may disclose any or all of the collected information to third parties.

We or these third parties may use the collected information to provide advertisements of interest to you on certain ValidClick Apps Services and non-affiliated websites and applications and for other purposes described in this privacy policy and to improve or customize our products.

D.    Do Not Track Signals

ValidClick Apps Services systems are not configured to respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services. The third-party services we rely on to deliver things like search results do typically honor “do not track” signals. Details for each service can be found in the privacy policy of the sites you use.

E.    Legal Basis for Processing Your Information

To process your information, we rely on the following legal basis:

·      Provide you with the ValidClick Apps Services: We process your information to run the ValidClick Apps Service. For instance, as you go about using our service, we use your information to provide you with a more customized and personal experience.

·      Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, ensure it is bug free, and we process information for administrative, fraud detection and other legal purposes.

·      Consent: From time to time, we may ValidClick for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

2. SEARCH APPLICATION COOKIES

The ValidClick Apps Product Add-on itself does not install Cookies. However, in order to access and use certain features of the Search Application services, we may use cookies and similar technologies (such as local stored objects) to collect and store information when you interact with the features of the Search Application. We, and certain third parties we work with e.g. ad networks and data management platforms, may also use these technologies to better target ads to you based on your online browsing activities.

If you do not accept the use of these cookies, please disable them by following the ‘opt-out’ links provided below or by changing your browser settings so that cookies from this Search Application service cannot be placed on your computer.

There are two (2) broad categories of cookies:

·      First party cookies, served directly by us to your computer.

·      Third party cookies, which are served by a third party. We use third party cookies for functionality, performance / analytics and advertising (including to target ads to you).

Cookies can remain on your computer for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by the Search Application to recognize your computer when you open your browser and browse the Internet again.

We use cookies to:

·      enable Validclick Apps and third-party advertising both on and off this Search Application, and evaluate the effectiveness of that advertising.

How to control or delete cookies:

You have the right to choose whether or not to accept cookies. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Search Application. Please follow the instructions on how to access and manage your browser.

If you want to limit certain third party advertising cookies, you can turn such cookies off by visiting the following links:

·      Your Online Choices (http://www.youronlinechoices.com)

·      Network Advertising Initiative (http://www.networkadvertising.org/)

·      Digital Advertising Alliance (http://www.aboutads.info/choices)

Please bear in mind that there are many more companies listed on these sites than those that drop cookies via the ValidClick Apps Services.

3. HOW WE USE THE INFORMATION WE COLLECT

We may use information that we collect about you to:

·      Deliver the ValidClick Apps Services to you;

·      Respond to your queries with the best possible answers and search results;

·      Provide you with customer support;

·      Perform research and analysis about your use of, or interest in, the ValidClick Apps Services, or products, services or content offered by others;

·      Enable us and our search and advertising partners to develop and display content and advertising tailored to your interests, when you use the ValidClick Apps Services;

·      Enforce our terms and conditions;

·      Manage our business and protect the quality of the ValidClick Apps Services, which includes maintenance of the ValidClick Apps Services systems;

·      Investigate complaints, abuse or other allegations; and

·      Perform functions as otherwise described to you at the time of collection.

In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

Sources of Information

A.    Information You Provide To Us: we may collect and store any information you provide when using the ValidClick Apps Services or that you provide in some other manner. This information may include information such as:

·       Your name and/or email address (in the provision of customer support/your data rights request).

Further, in order to permit us to protect the quality of our products and services, we may to the extent permitted by applicable law access your account and records on a case by case basis to investigate complaints or other allegations.

B.    Automatically Captured Information: we automatically collect information from your computer and/or device when you use the ValidClick Apps Services. This allows us to assess how you have used the ValidClick Apps Services, the device you have used them on and helps us to analyze how we can optimize the ValidClick Apps Services for you in the future. This information may include:

·       Information about your hardware and software such as your IP address, your browser type and language and other browser-related information and a timestamp.

·       Information about how you use the Search Applications such as the keyword query, search query text, search results clicked, pages viewed and search history.

·       The content of any of our undeleted cookies, including a unique identifier, software installed upon and/or devices connected to your computer and/or device, and the referring website address.

C.    Other Technologies: we may use standard Internet technology, such as web beacons, cookies and other similar technologies, to track your use of the ValidClick Apps Services. Web beacons are small pieces of data that are embedded in images on the pages of sites. The information we obtain in this manner enables us to customize the services we offer as part of the ValidClick Apps Services for our users.

D.    Third Parties:

Third Parties: we may allow third parties, including our authorized service providers, parent and subsidiary companies, affiliates, advertising companies, and ad networks, to display advertisements or place ad tags or beacons on or via our Services on the computer or device you use to access our ValidClick Apps Services and to track that device to over time and across different web sites for the purpose of serving advertising relevant to your interests. We do not control third parties’ collection or use of information to serve interest-based advertising. Some but not all providers may allow you to opt-out of receiving their targeted ads, see http://www.networkadvertising.org/choices/.

This Privacy Policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, resources to which our Services may link or that you may access through the Services. If you are using a version of the Service that includes third party services, such third party features, functionalities and content are subject to such third party’s privacy policy.

The use of information received from Google APIs will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.

E.    Do Not Track Signals: ValidClick Apps Services systems are not configured to respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services.

To process your information as described above, we rely on the following legal basis:

·       Provide you with the ValidClick Apps Services: most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to provide you with a more customized and personal experience.

·       Legitimate interests: we may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, ensure it is bug free, and we process information for administrative, fraud detection and other legal purposes.

·       Consent: from time to time, we may ValidClick for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by either contacting us at the address provided at the end of this Privacy Policy.

5. WITH WHOM WE SHARE YOUR INFORMATION

We share your information with others as indicated below:

A.    Authorized service providers: We may share your information with our authorized service providers that perform certain services on our behalf. In certain instances, these service providers may collect information directly from you on our behalf. These services may include:

·      providing customer service, technical and operational support;

·      marketing assistance, performing business and sales analysis; and

·      supporting our ValidClick Apps Services functionality, as well as when you have requested that we do so, including processing your search queries.

These service providers may have access to information, which is needed to perform their functions and provide you with the ValidClick Apps Services.

B.    Advertisers and Ad Networks: As described above advertisers and ad networks, and other third parties may collect information themselves from the ValidClick Apps Services (or we may provide them with the information described above) for purposes of delivering relevant ads. This assists us in advertising our services and in providing you with relevant ads based on your browsing interests.

C.    Business partners: When you engage with content offered through the ValidClick Apps Services, we may share information with the businesses with which we partner to offer you those products and/or services.

D.    Affiliates: We may share your information with our affiliates, which are entities under common ownership or control of our ultimate parent company, Inuvo, Inc. for security, internal reporting and regulatory compliance or for business intelligence to improve user experience.

E.    Other Situations: We may disclose your information (i) in good faith compliance with a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce our terms and conditions or other agreements or policies; and (vi) in connection with a corporate transaction, such as the sale of all or a portion our business or products, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.

6. HOW LONG WE KEEP YOUR INFORMATION

We only keep your personal information as long as it is necessary for the purposes set out in this Privacy Policy including for legitimate business purposes and as permitted by applicable law. We will only use your information to the extent necessary to comply with our legal obligations, resolve any legal issues, enforce our agreements, and as otherwise described in this policy.

7. WHERE WE STORE YOUR INFORMATION

Information we collect, or permit third parties to collect may be transferred to, stored and processed outside your country of residence in any country or territory where one or more of our affiliated group companies, third party service providers or advertising companies or advertising networks are located or maintain facilities, including but not limited to the United States.

When your information is moved from your home country to another country, we ensure that such a transfer is done legally. For users based in the European Economic Area (“EEA”), we may rely on the Model Clauses a standard document created by the European Commission to facilitate data transfers while ensuring that safeguards are put in place for personal information. We do not participate in the EU-US Privacy Shield, but we may rely on it to transfer personal information to some of our service providers based in the USA, provided they are certified to receive such personal information pursuant to the Privacy Shield.

8. THIRD-PARTY WEBSITES

There may be places in the ValidClick Apps Services where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy policy of all third-party websites you visit.

9. YOUR DATA RIGHTS

You may have some or all of the following rights in relation to how we use your information:

·      Access: you may request access to your information and receive copies of it.

·      Correction: to have inaccurate/incomplete information corrected and updated.

·      Object to, or Limit or Restrict, Use of your Information: You can ValidClick us to stop using all or some of your information or to limit our use of it.

·      Deletion: in certain circumstances, you can request a right “to be forgotten” (this is a right to have your information deleted or our use of your information restricted, including for example, a right to not have a user’s name appear in a search result). We will honor such requests unless we have to retain this information to comply with a legal obligation by European or Member State law or unless we have an overriding interest to retain it.

·      Portability/The Right to Obtain your Personal Data: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your information to transfer to another provider).

·      Consent Management: Where we rely on consent to process your information, you may withdraw consent at any time.

If you wish to exercise any of these rights or wish to object to our use of your information, please see our “How to Contact Us” section below. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person.

10. CHILDREN’S PRIVACY

Our ValidClick Apps Services are intended for general audiences over the age of 18 years old. We do not knowingly collect information from children under the age of 18 years old. If you are not over 18 years old, then DO NOT DOWNLOAD OR USE THE VALIDCLICK APPS SERVICES.

11. HOW WE PROTECT YOUR INFORMATION

The security and confidentiality of your information is very important to us; thus, we take certain security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. Please know that, despite our best efforts, no security measures are perfect or impenetrable.

12. CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect changes in our practices and services. We recommend that you check this page, or the help menu within an ValidClick Apps Service, from time to time to inform yourself of any changes in this Privacy Policy.

13. INFORMATION FOR RESIDENTS OF CALIFORNIA: YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@inuvo.com

We adopt this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. This section applies solely to all visitors, users, and others who reside in the State of California.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Our ValidClick Services obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Websites and / or advertisements.

Use of Personal Information 

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. 
• To provide, support, personalize, and develop our Websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our [Website users/consumers] is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

The CCPA defines “sale” very broadly and includes the sharing of CCPA PI for anything of value.  According to this broad definition, we may also share your Personal Information by selling it to third parties, subject to your right to opt-out of those sales. In the preceding twelve (12) months, Company has sold the following categories of Personal Information to the categories of third parties indicated in the chart below. 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Address 1:

ValidClick, Inc.
500 President Clinton Avenue
Suite 300
Little Rock AR 72201
Attn: Privacy Officer

Address 2:

privacy@validclick.com
or you may call our toll-free number at (800) 583-1560.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. You have the right to make or obtain one transportable copy, no more than twice in a twelve-month period, of your Personal Information that we have collected in the period that is 12 months prior to the request date.

When you assert your right to request information, you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include confirmation that you are a resident of the State of California.  We reserve the right to request that you provide further evidence as a resident of California before acting on your request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Any request you submit to us is subject to an identification and residency verification process and must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. For more information on why we have collected data about you, please see the rest of this Privacy Policy and our Terms.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

To opt-out of this site selling any of the information it collects about you to third parties and to delete all such information, we offer an “Opt-Out” Option, which can be accessed via the following page: https://optout.networkadvertising.org/.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

14. YOUR NEVADA RIGHTS

Under Nevada law, Nevada residents may opt out of the “sale” of certain “covered information” (as defined under Nevada law) collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by Nevada law, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us at privacy@validclick.com. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.

15. CONTACT US

If you have questions about our privacy policy, please contact us at privacy@validclick.com or by mail at:

ValidClick, Inc. Attn: Marketing and Communications, 500 President Clinton Ave, Suite 300, Little Rock, AR 72201