This Privacy and Cookies Policy describes the privacy practices relating to information that CloutHQ, Inc. (“CloutHQ,” “we,” “us,” “our”) collects and uses on our websites that link to this policy, such as www.CloutHQ.com or any other website where this policy is displayed (collectively, our “Site”), as well as through our analytics technology services that our clients use on their websites and their mobile applications (our “Services”).
1. Information We Collect Through Our Services and How We Use It
Among other services, we provide analytics that allows advertisers, websites, and app developers, to better understand the effectiveness of their content, including online advertising. We may help Clients understand, for instance, whether their branded posts on social media tend to be viewed by users, and whether their articles or ads appear in a viewable manner. In providing these Services, we may work with business partners who collect and provide us with information collected from users’ browsers or devices. The information that we or they may collect through our Services (referred to in this Privacy and Cookies Policy as the “Service Information”) includes the following:
Log information. When users visit a website where our Services are deployed, our servers may automatically record information that each browser sends. These server logs include information such as Internet Protocol (“IP”) address (a unique number that is automatically assigned to your computer), the date and time, browser type, and users’ interactions with our Clients’ content and advertising.
Mobile data. Through mobile applications on which our Services are deployed, we (or Clients and other application providers we work with) likewise may collect information about users’ interactions with those applications (including your IP address and time-stamp information), and information about users’ mobile devices (including device type, handset name, operating system information, mobile identifiers such as Apple IDFA and Android Advertising ID, app-specific identifiers, and a list of the applications devices interacts with).
We, our business partners or Clients may collect information about your browser, device, and how you interact with web and mobile content, through the use of cookie IDs associated with your browser. We or they may deploy and read these unique IDs, and thus passively “collect” them, when you go to a Site where our Services are deployed or (as to our business partners) where they otherwise interact with a user’s browser. For more details about these technologies, please see the section further below titled “Cookies”, “Pixel Tags,” and “SDKs,” and How We Use Them.
We may combine any of the above Service Information with each other, and we may also combine it with information or inferences about users’’ interaction with ads, content, and webpages or applications that our clients provide or display (“Viewing Data”).
2. Information We Collect On Our Site and How We Use It
We collect the following information from users, whether passively or actively, when users visit our Site (“Site Information”):
Volunteered: You may share personal information with us when you subscribe to our newsletter, open an account with us, fill out a form on our website, purchase our products or services, or interact with us in other ways. The information you would share in these cases typically would be contact information (e.g., name, email address, and phone number) or billing/payment information. You do not have to share this information with us, but without it, you may not be able to access certain content, features, or services.
Cookies and Unique IDs: Like most web businesses, we use automated mechanisms (e.g., cookies and pixels) with unique identifiers to keep track of user interactions with our Site. (Learn more about these technologies by scrolling to our Section titled “Cookies,” “Pixel Tags,” and “SDKs” and How We Use Them.) We may use our own technology (as described in Client Services above) for that purpose, and we also may use third-party services such as Google Analytics, in which case those third parties gather information such as your IP address, browser type, the webpage from which you came to our website, and the times of your access to our Site.
In addition to the uses described above, we use this “Site Information” (alone or in combination) to provide, market, and operate our Site and Services. Among other things, the Site Information we collect can enable us to:
Maintain the Site and Services, and optimize the way our Site and Services are offered,
Send you requested product or service information,
Respond to your questions, concerns, or customer service inquiries,
Customize the content and advertising you see on our Site, across the Internet, and elsewhere, and
Send you marketing and other communications.
We will only process personal information you provide to us or we collect in accordance with applicable data protection laws including, in the case of users located in the European Union, applicable laws which implement the Data Protection Directive 95/46/EEC, the Privacy and Electronic Communication (EC Directive) Regulations 2003.
3. How We Share the Service Information and Site Information
We share the Service Information (such as the Viewing Data) with our Clients and their service providers and other platforms that may assist those Clients.
We share the Site Information with companies that help us operate our platform and market our services, such as to advertise our services, bill our customers, analyze our Site performance, provide customer and technical support, hosting services, and other operational support.
We may share the Site and Service Information as follows:
As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).
With any subsidiaries which are partly or fully owned by corporate affiliates.
With third parties that help us to provide the Site or Services, such as entities that help make our Site or Services available and functional, host our content and services, make available or transmit any information we hold, help us send emails, help us process payments, help us manage customer information, or other subcontractors, affiliates, and consultants which provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our Clients.
If required by law or in response to legal process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official.
Where we believe sharing the information may prevent physical, financial or other harm, injury or loss; or we believe is necessary for protecting our interests; or is in connection with an investigation of suspected or actual unlawful activity.
We also may disclose your information under circumstances not mentioned here with prior consent of the user that submitted the information to us.
4. “Cookies,” “Pixel Tags,” and “SDKs,” and How We Use Them
Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, or make use of e-billing services.
Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Site or our Clients’ websites. This helps us and our Clients to improve the way that the websites work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our Site or our Clients’ websites. This means that content can be personalized for you and your preferences can be remembered (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our Site or our Clients’ websites, the pages you have visited, and the links you have followed. This information will be used to make the websites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.
Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or publisher-facing and app developer platforms that use mobile SDKs to collect information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and information connected to how mobile devices interact with our Services and those using our Services. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. The SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this technology, for instance, to analyze or measure certain advertising through mobile applications and browsers based on information associated with your mobile device. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the below Section titled “Your Choices, and Your Opt-Out Options”
Sometimes, our Clients or partners we work with may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or hashed or de-identified data files) to coordinate users’ identities across platforms, browsers or devices, to more efficiently analyze online or mobile audiences, or target advertising and analyze ad performance.
5. Your Choices, and Your Opt-Out Options
We sometimes work with companies that capture anonymous or de-identified data and create targeting attributes based on users’ online browsing activities. You may opt-out of these third parties services (and learn more about them) by visiting the Digital Advertising Alliance’s opt-out page, or the Network Advertising Initiative’s opt-out page, or, if you are a European user, by visiting www.youronlinechoices.com . Please note that opting out through this page will generally only opt-out of these companies’ “third party” ad targeting features; you will continue to see non-tailored ads.
Similarly, to provide or use our Services, we (or Clients and partners we work with) may employ other information collected from users when they are online (for instance, IP address), aggregated with information collected from various websites and mobile applications, and various devices or browsers. The above industry-provided opt-out pages can also opt you out of many of those types of services. Other consumer choice tools are provided through the website, including the browser extension, Enterprise the opt-out program), and information about the Control application through which you may enable information “opt outs” for mobile applications or web sites.
To opt-out of our data service, please follow these steps:
Download and install the extension (which will provide you a variety of opt-out choices, in addition to permitting you to block our data collection);
Once installed, enable the Ghostery Findings Panel;
You will then have the ability to block our service from collecting data, when our service appears in the Ghostery Panel.
Please note that Ghostery may implement updates or changes to its features, and they (not we) control those features.
We also sometimes work with companies that capture advertising identifiers from mobile devices. You may opt out of using these identifiers for purposes of interest-based advertising by accessing the settings on your phone.
6. Third Parties on our Own Site
As on most websites, third parties may directly gather user information from users of our Site through automated means such as cookies or pixels. For example, our third party video hosting provider may use Flash cookies to collect and store information, such as your volume control preferences. Cookie management tools provided by your browser may help you manage certain types of cookies but may not work with other kinds, such as Flash cookies.
In addition, the Site may contain embedded third-party content or links to third party websites and content. Our service does not control these websites and/or content, and these third parties’ privacy policies are different from our own. You access linked websites or third party content at your own risk. We are not responsible for the privacy practices of these websites or content providers, and you should check their applicable privacy policies to determine how they handle any information they collect from you.
7. Information Security
We take measures to protect against unauthorized access to or unauthorized alteration, interference, disclosure, or destruction of data we collect and store. These may include, for instance, internal reviews of our data collection, storage, and processing practices, and security measures. Our servers are protected by firewalls and are physically located in secure data facilities to further increase security. Of course, no security system is perfect. While we take a range of measures to safeguard against unauthorized access to the data we collect and store, we cannot guarantee that it will not be disclosed or accessed inadvertently or through the unauthorized acts of others.
8. International Transfers
We may transfer personal information that we collect from you to third-party data processors or to members of our group of companies located in other countries in connection with the above purposes. Data that we collect will be stored on servers in the United States or in other territories. Please be aware that countries that are outside your country of residence may not offer the same level of data protection as your country of residence, although our collection, storage, and use of your personal data will continue to be governed by this Privacy and Cookies Policy.
9. Your Rights
If you are a resident of Australia or of a European Union Member State, you have the following rights:
the right to request access to, or ask us to provide you with copies of, personal information that we hold about you at any time, which may be subject to a fee specified by law for processing your request (but not for making a request for access). We will respond to your request within a reasonable period. We may decline a request for access to personal information in circumstances prescribed by relevant privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
the right to ask us to update and correct any out-of-date or incorrect or inaccurate personal information that we hold about you free of charge. We will take reasonable steps to correct the information so that it is accurate, complete, and up to date. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint; and
the right to opt-out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you. If you wish to exercise any of the above rights, please write to us (either by e-mail or by mail) using the contact details in section 11 below.
10. Changes to Privacy and Cookies Policy
We reserve the right to change this Privacy and Cookies Policy without prior notice at any time and will do so by posting the updated version on our Site.