PRIVACY POLICY

Last updated: August 24, 2020

Proclivity Systems, Inc. (“Proclivity,” “we,” “our,” or “us”) operates a technology and analytics platform (the“ Platform”), which provides data analytics and advertising related products and services for our clients (“Client Services”). This Privacy Policy explains what information we may collect, how such information may be used and/or shared with others, and how you may access and control its use in connection with our business communications and activities, such as our Client Services. This Privacy Policy applies when you visit our website(s) at www.proclivitysystems.com or any other sites where Proclivity performs web event collection on behalf of our clients.

Table of Contents

  • Information Collection

  • Information Use

  • Information Sharing

  • Digital Advertising & Analytics

  • Consumer Rights

  • Third Party Sites & Tools

  • Security

  • Children’s Privacy

  • Updates to this Privacy Policy

  • Contact Information

Information Collection

When using our Site(s), you may voluntarily provide information about yourself, including your name, email address, and any other information you choose to provide (“Visitor Data”) in order to request and receive additional information about Proclivity’s products and services, to inquire about a career opportunity, or to interact with us for any other purpose. Visitor Data collected on behalf of our clients also consists of clickstream information, Internet Protocol address (“IP address”), browser type, device type, pages visited, content clicked, and other information on the Site. Visitor Data is used to improve the sites, as well as offerings and promotions of Proclivity and others’ products and services. In addition, we may also work with and share this information with third parties for analytics assessment of site Visitor Data and site performance.  

In offering our Client Services through the Proclivity Platform, we collect information about our clients’ site visitors, from site visitors or from our clients (“Client Services Data”). Client Services Data includes:

  • Certain information about individuals’ internet activity, including IP address, device identifiers, browser information, interaction with website content, pages viewed, app usage, and other such information.

  • Digital identifiers (cookies, device IDs, etc)

Information Use

We may use Visitor Data for any lawful purpose, including the following:

  • To respond to your inquiries;

  • To operate and improve services, including to provide better services, products, and opportunities to our clients and visitors to their Site;

  • To operate, personalize, and improve Sites, including for analytics purposes;

  • To send surveys, promotions, and marketing materials that may be of interest to you;

  • To comply with the law and to maintain the security of the Sites; or

  • With your consent, or as otherwise disclosed at the time information is collected.

Proclivity’s Platform. Proclivity’s proprietary system analyzes information to develop insights about individuals’ interests in order to deliver or enable clients to deliver relevant and targeted products, services and advertising or other content. Our clients determine, manage and are responsible for the privacy practices and choices available to their customers regarding Client Services Data. We may use Client Services Data for any lawful purpose consistent with our contractual relationships with our clients, including the following:

  • To respond to our client’s inquiries;

  • To operate and improve our services, including our Client Services, and to better our Platform and services;

  • To perform research and product development;

  • Measure the performance of advertising campaigns and generate reports, analytics and other assessments that Proclivity may provide to clients or in anonymous or aggregate form to third parties;

  • With our client’s consent or at their direction. We may use information that has been de-identified or aggregated without limitation.

Information Sharing

We may share the information we collect with other parties, including the following:

  • With third party vendors who process data on our behalf, only to provide Services to us and our clients, such as other sell-side platforms (SSPs);

  • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;

  • Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties;

  • With your consent or as otherwise disclosed at the time of collection or sharing; or

  • With our client’s consent or at their direction.

      

We may share information that has been de-identified or aggregated without limitation.  

Digital Advertising & Analytics

We may partner with other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices.  This type of advertising is known as interest-based advertising.

For information that Proclivity collects directly from site visitors, Proclivity provides individuals the choice to opt out of interest-based advertising. If you do not want to receive interest-based advertising, click here to opt-out. If you choose to opt-out, Proclivity will deploy an opt-out cookie to your browser and will not serve interest-based advertising to you when you are viewing websites via that browser. You may continue to see advertising, but that advertising will not be targeted by Proclivity to match your interests. You can also control cookies via your browsers, which can be set to limit, block or delete cookies. However, such browser changes may impact the effectiveness of the opt-out choice provided by Proclivity via an opt-out cookie, and individuals will need to repeat the opt-out process after changing browsers, computers or deleting their cookies.

For its client services, Proclivity adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles in connection with interest-based advertising activity. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choice by revisiting the Proclivity opt-out page here. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, some Sites may not function as intended.           

Consumer Rights

Nevada Privacy Rights

Although we do not currently conduct sales of personal information under Nevada law, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future. To exercise this right as it relates to Visitor Data defined as personal information under Nevada law, please contact us:

  • By email at privacy@proclivitysystems.com

Your California Rights

The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their “personal information” that is subject to the CCPA. This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to Visitor Data that is “personal information” subject to the CCPA. Personal Information We Collect.  In the preceding 12 months, we collected the following categories of personal information about California consumers.

 
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Categories of Sources. We collect personal information from the following categories of sources:

  • Consumers;

  • Publisher partners;

  • Data analytics providers;

  • Advertisers.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy.  These commercial and business purposes include, without limitation:

  • Our commercial purposes, including enabling and verifying commercial transactions, and producing aggregated business analysis.

  • Our business purposes as identified in the CCPA, which include:

    • Auditing related to our interactions with you;

    • Legal compliance;

    • Detecting and protecting against security incidents, fraud, and illegal activity;

    • Debugging;

    • Performing services (for us or our clients) such as account servicing, processing orders and payments, and analytics;

    • Internal research for technological improvement;

    • Internal operations;

    • Activities to maintain and improve our services; and

    • Other one-time uses.

Recipients of California Personal Information.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses.  If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.

  • The right to request that we delete the personal information we have collected from you.

  • The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.

  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.  We will require you to provide, at a minimum name, email, residency and residency, which will only be used to process or verify your request. You will be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If you are exercising your right to access, portability or deletion, you may be asked to provide further verifying documentation, such as proof of residency and identity.

Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Third Party Sites & Tools

Our Site(s) may contain links to other sites whose information practices may be different than ours. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. Visitors should consult the other sites’ privacy policies before submitting any information, as these third-party sites are responsible for information that is submitted to, collected or used by them.

Our Site(s) may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties.  If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.  Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features.  We encourage you to carefully read the privacy policies of any accounts you create and use.

Security

Proclivity uses standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of information in our systems. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that information in our systems is no longer secure (for example, if you feel that our security may recently have been compromised), please notify us immediately in accordance with the “Contacting Us” section below.

Children’s Privacy

Proclivity is committed to protecting the privacy of children. Neither Proclivity’s corporate website nor its services, including its Client Services, are intended or designed for children under the age of 16. Proclivity does not knowingly collect any personal information from a child under 16. If you believe that we might have any information from a child under 16, please contact us as directed below in the “Contacting Us” section.

Updates to This Privacy Policy

We may periodically update this Privacy Policy.  Please reference the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our website.  Your use of Proclivity services following these changes means that you accept the revised Privacy Policy.

Contact for More Information

For questions or concerns about Proclivity’s Privacy Policy or practices, please contact us by using the information below.

By email: privacy@proclivitysystems.com

By mail:

Privacy 
Proclivity Systems, Inc. 
33 West 17th Street 
4th Floor 
New York, NY 10011