Any request for a disclosure required under this law or a notice to opt out of this collection of private information should be sent to us via email at email@example.com. Please note that under this law, we are not required to respond to a customer’s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email address designated above.
Persons Under the Age of 18.
We do not knowingly collect personal information from persons under the age of 18. If we discover we have collected or received personal information (see below) from a child under 18 without verification of parental consent, we will delete that information upon request. If you believe we might have any information from or about a person under age 18, please email us at firstname.lastname@example.org.
We collect three types of information: personally identifiable information, aggregate and anonymous information, and user activity information.
Personally Identifiable Information
Personally Identifiable Information (or “PII”) is any information that can identify or is linked to a specific individual, such as your name, mailing address, telephone number (including mobile number), email address, credit card number, debit card number, bank account number, and other financial account information, birth date, gender, occupation, personal interests, demographic, location and household information, etc. To the extent you voluntarily provide your PII to us, we collect such information.
It is optional for you to engage in an Identification Activity. However, if you elect to engage in an Identification Activity, we may ask you for certain PII. Depending on the activity, some of the information we ask you to provide may be identified as mandatory and some may be identified as optional. If you do not provide the mandatory information for a particular Identification Activity that requires it, you will not be able to engage in that activity. In addition, if you use our Website or a linked site to send information to another person (e.g., a friend, a family member, etc.), we will also collect PII of that other person to the extent disclosed by you. We also collect the username and password for the email account you wish to import your contacts from, for example, and will only use it for that purpose.
Aggregate and Anonymous Information (hereinafter “AAI”) is any information that cannot identify or be linked to a specific individual. For example, we may collect anonymous group data (demographics, media habits, online browsing habits, interests and preferences, etc.) about users and members of our Website or a linked site, etc. (hereinafter referred to collectively as “our Audiences”). We may also collect aggregate traffic data pertaining to our Website or a linked site, such as: total page views in a given time period; total impressions per ad; average amount of time that visitors spend on our Website or a linked site (or a part thereof) each time they visit; average amount of time that visitors spend on each page of any one or more parts of our Website or a linked site; percentage of visitors from a certain geographical area, etc. Moreover, we may combine “User Activity Information” (as described below) about you and other users of our Website or a linked site to generate aggregate information that reflects activities, habits, preferences, interests, etc. about our users as a group. We also collect location-based information such as zip code, city and state name. In addition, we may take PII and make it non-personally identifiable, such as by aggregating your information with information about other individuals, or by removing personally-identifiable elements (such as names) so as to “anonymize” or “de-personalize” your information.
Non-Personally Identifiable Information
We may collect information (including PII) from you in different manners and at different places and times on this Website, such as when you register for this Website or subscribe to a mailing list or information through an Online Product. The following is a description of the areas and/or manners in which we primarily collect information about you.
Cookies, Action Tags, Third Party Media and DoubleClick
We also collect AAI passively using “cookies” and “action tags.” There are other ways information can be used by third parties.
“Cookies” are small text files that are placed on your computer in order to identify (i) your Web browser (ii) the activities of your computer on this Website and (iii) your activity in connection with our advertisements and other marketing and promotional efforts. Cookies may be used to:
- 1. Personalize your experience on this Website (e.g., to dynamically generate content on WebPages specifically designed for you);
- 2. Assist you in using our Online Products (e.g., to save you time by not having to reenter your name upon each visit to this Website); and
- 3. Allow us to statistically monitor how you are using this Website for purposes of improving our online offerings.
In addition to cookies that we place on your computer, cookies may also be placed on your computer by third parties that we use to display or serve advertisements or to collect AAI to provide advertising-related services. In the course of serving advertisements, our third-party advertiser may place or recognize a unique “cookie” on your browser.
You do not have to accept cookies to use this Website. However, you may not be able to use certain products, offerings, features, or resources of this Website (including our Online Products) if you do not accept cookies. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar.
“Action tags,” also known as web beacons or GIF tags, are a web technology devices used to help track anonymous website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of this Website, including advertisements, or e-mail sent on our behalf, may contain cookies that are associated with action tags that are located on this Website. Unlike cookies, action tags are not placed on your computer.
Description and purpose
In addition to strictly necessary cookies, we also use analytical cookies, which help us to identify our users and offer them the best experience when browsing our site. They also allow us to track navigation data and analyze it in order to make enhancements to our website. Finally, we use behavioral/advertising cookies to manage ads spots according to the user’s specific profile. The sale of advertising spaces allow us to offer you free useful content.
Emails to PULSE
What does this Website do with the information it collects?
What We Do With the Information
As a general matter, we use information (PII and AAI) collected from and/or about our Audiences to improve our products and services so that they are appealing to as many people as possible, to administer and maintain operations of our Website or linked sites, to offer, market and advertise products and services (including those from third parties outside PULSE with whom we do business (hereinafter referred to collectively as our Business Partners”)) to our Audiences, to administer and manage transactions and relationships with our Audiences, to personalize user experiences for our Audiences, and to build a strong community for our Audiences.
Our Own Use of Information
Marketing Advertising Purposes
(1) Interest-based advertising on our Website or linked sites: We may use your PII and UAI to provide to you interest-based ads (i.e., ads potentially relevant or tailored to your interests) about products and services of PULSE and/or our Business Partners. For example, we show ads inside and/or alongside the videos you watch on PULSE’s Website. Sometimes, these ads are based on the topics or subject matters of the videos you are watching. However, to make these ads as relevant as possible for you, we may infer your viewing interests based on videos you have previously viewed on PULSE’s Website and may use this information to associate your browser with relevant interest categories and show you ads relevant to your inferred interests. For example, if your prior viewing habits on PULSE’s Website suggest that you are interested in a particular topic (e.g., if you often review items on that topic on PULSE’s Website), you may see more ads related to that topic while on PULSE’s Website.
(2) Email marketing If you provide your email address or mailing address to us (such as by joining one of our mailing lists), we may use such address to send you product and service offers, promotions, and advertisements from us and/or from our Business Partners. See “Opt-Out” below regarding how to opt out of our email marketing.
(3) Telemarketing If you provide your telephone or mobile number to us, we may call you to inform you about product/service offers, promotions, and advertisements from us and/or from our Business Partners. See Opt Out below regarding how to opt out of our telemarketing.
(4) Mobile marketing Subject to your PRIOR OPT IN CONSENT, we may (i) send marketing and advertising messages via SMS (Short Message Service), MMS (Multimedia Message Service), etc., to your mobile device and/or (ii) send marketing and advertising emails to your wireless email account (e.g., XYZ@att.mobile.net), to inform you about product/service offers, promotions, and advertisements from us and/or from our Business Partners. See Opt Out below regarding how to opt out of our mobile marketing (that is, if you wish to opt out of our further use of your information for mobile marketing after you have previously consented to such use).
(5) Market Research Purposes: We may use AAI (including UAI and AAI derived from PII) to conduct market research and analysis for ourselves as well as for our Business Partners.
Disclosure to Third Parties Outside PULSE
(1) Disclosure to our Business Partners We may disclose, sell, and otherwise provide PII, AAI and/or UAI to our Business Partners so that they may market and advertise their products and services directly to our Audiences. See “Opt-Out” below regarding how to opt out of such information sharing.
Please note, however, that we do not knowingly disclose or sell any of the following (if and to the extent collected by us) to our Business Partners for their separate marketing and advertising purposes (except with your prior opt-in consent): credit card number, debit card number, bank account number, and other financial account information; Social Security numbers, or other government-issued identifiers; personal health and medical information; information about personal sexual behavior or orientation; information pertaining to children under the age of 13 at the time of collection; and information indicating the precise real-time geographic location of an individual derived through location-based services such as through GPS-enabled devices (hereinafter referred to collectively as “Sensitive Information”).
In addition, from time to time, we may co-sponsor events and/or product/service offerings with third parties. If you participate in such co-sponsored events or offerings, any PII and UAI we collect from you based on your participation may be shared with our co-sponsors who may use such information for their own marketing and advertising purposes. YOU MUST CONTACT OUR CO-SPONSORS DIRECTLY IN ORDER TO OPT OUT OF THEIR USE OF YOUR INFORMATION FOR MARKETING AND ADVERTISING PURPOSES.
(2) Disclosure to our Service Providers We may disclose PII and UAI to our outside vendors and contractors who need to access such information in order to perform services (including, without limitation, transaction/payment processing, order fulfillment, contest/sweepstakes administration and prize fulfillment, data research and analysis, data collection and processing, data storage, data security, hosting and technical support for our Website or linked sites, and marketing and advertising support) for us (hereinafter referred to collectively as “our Service Providers”). Generally, we require that our Service Providers use your information shared by us solely for the purposes of performing services for us and that they maintain the confidentiality, security and integrity of such information and not further disclose the information to others.
Laws and Legal Rights
We may also disclose your information (including PII) if we believe in good faith or on advice of counsel that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose PII in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms and Conditions or to protect the safety or security of our users, this Website or the general public.
Sale of Business
We will retain your PII for as long as your account is active or as needed to provide you products or services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. AAI and UAI (if not personally identifiable) may be retained indefinitely.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your PII may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all PII stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable.
Whom do I contact if I have any privacy questions?