Effective Date: October 4, 2018
Thank you for visiting the Three Spring Media performance marketing partner network website
(the "Site"). Three Spring Media ("we", "us") is committed to protecting the privacy of
your personally identifiable information. We provide this privacy policy
("Privacy Policy") in order to explain our online information practices
and the choices you can make about the way your information is used by
us. You must agree to this Privacy Policy, in its entirety, including
our use of cookies in order to: register an account ("Account") with the
Three Spring Media performance marketing partner network ("Performance Marketing Partner Network") and log in to your Account as
member of the Performance Marketing Partner Network. If you do not agree to this Privacy
Policy in its entirety, you are not authorized to register for an
Account on the Performance Marketing Partner Network.
Privacy Policies Used in Connection with Your Subscription.
When you register for an Account on the Performance Marketing Partner Network, we use a
password-protected third-party portal to store your personal
information, and we may share your personal information with such third
party ("Third Party Agent") as is necessary for the performance of your
Account and the Performance Marketing Partner Network.
Personally Identifiable Information.
We collect personally identifiable information when you register for an
Account or otherwise choose to provide personally identifiable
information to us. Personally identifiable information is any
information that can be used to identify or locate a particular person
or entity. This may include but is not limited to: business entity name
and/or your title with the applicable business entity, as well as your
personal and/or business entity related e-mail address, mailing address,
daytime and/or cellular telephone numbers, fax number, account
information (or other information that we require in order to pay any
amounts due to you under the Performance Marketing Partner Network), IP address and/or any
other information requested on the applicable Subscriber registration
form.
Non-Personally Identifiable Information.
We may collect certain non-personally identifiable information about you
when you visit certain pages of this Site and/or register for an Account
on the Performance Marketing Partner Network, such as the type of browser you are using
(e.g., Chrome, Internet Explorer), the type of operating system you are
using, (e.g., Windows or Mac OS) and the domain name of your Internet
service provider (ISP) and share such information with our Third-Party
Agent. We use the non-personally identifiable information that we
collect to improve the design and content of the Site and to enable us
to personalize your Internet experience. We also may use this
information in the aggregate to analyze Site usage.
Cookies and Web Beacons and Ad Identifiers.
To enhance your experience with the Site, we use "cookies." Cookies are
small packets of data stored on your computer used to store your
preferences. Cookies, by themselves, do not tell us your e-mail address
or other personally identifiable information. You may set your browser
to warn you that cookies are in use, or to block the use of cookies. We
use strictly necessary cookies to allow you to move around the Site and
log in to your Account, and functional cookies to improve the services
and support available to you. Accepting strictly necessary cookies is a
condition of using the Site. You can control whether or not functional
cookies are used, though preventing them may mean some services and
support will be unavailable. Cookies may be managed for us by third
parties; where this is the case, we do not allow the third party to use
the cookies for any purpose other than as necessary to provide the
services.
We may additionally collect information using Web beacons, which are
commonly referred to in the industry as web bugs, pixel tags or Clear
GIFs. Web beacons are electronic images that may be used on the Site, in
your Account, or in our emails to deliver cookies, count visits and
determine if an email has been opened and acted upon.
End users can disable cookies in most internet browsers. An overview of the process is available
at http://www.allaboutcookies.org/manage-cookies/. Disabling cookies will not, however, stop
receipt of all advertisements. If an end user would like to opt out of a particular ad network,
publisher, or advertiser’s ads, they will need to contact those companies directly to inquire
whether they have an opt-out option.
End users can also disable collection of ad identifiers for targeted advertising by enabling the
Limit Ad Tracking setting on their smartphone. End users can also reset the ad identifier
altogether using their smartphone’s privacy settings
We may be a participant of the Google Third Party Serving Compatibility Program, in which
case we would abide by the Third-Party Ad Serving Policy available at
http://adwords.google.com/support/bin/answer.py?answer=94230
Use of Information.
We use your personally identifiable information: (a) to send you
information regarding your Account and the Performance Marketing Partner Network; (b) to
track your compliance with the Terms and Conditions ("Terms and
Conditions"); and/or (c) for validation, suppression, content
improvement and feedback purposes. In addition, we may use your IP
address for the purposes identified above, as well as to analyze trends,
administer the Site, track users’ movements, gather broad demographic
information for aggregate use, and to confirm that a particular
individual affirmed his/her consent to specific legal terms (e.g. a
clickwrap license agreement). You agree that we, or our Third Party
Agent, may contact you at any time regarding your Account or the
Performance Marketing Partner Network and/or any other information that we may deem
appropriate for you to receive in connection with your Account on the
Performance Marketing Partner Network. You may update your contact preferences as set forth
below.
Information Sharing.
As a general rule, and other than in connection with the limited
exceptions set forth below, we will not sell, share or rent your
personally identifiable information to or with others. Notwithstanding
the foregoing, we may, from time to time, provide such information to
certain third-party administrative vendors, including HasOffers, for
efficiency purposes in providing administrative or program management
services in connection with your Account. Any third-party vendor so used
has agreed to protect the confidentiality of information provided by us.
Further, we reserve the right to share your personally identifiable
information: (a) where required by law, or requested by a court of
competent jurisdiction; (b) in the event of any reorganization, merger,
sale, joint venture, assignment, transfer or other disposition of all or
any portion of our business, assets or stock; (c) where you are in
violation of this Privacy Policy, the Terms and Conditions and/or
Services Agreement; (d) in the case of a dispute; or (e) where we
determine, in our sole discretion, that such disclosure is necessary to
protect our rights and/or a third party, or necessary to protect us from
liability of any kind. The aforementioned includes exchanging
information with other companies and organizations for fraud protection.
International Transfer of Data.
We may transfer information that we collect about you and your end
users, including personal information, to affiliated entities, or to
other third parties across borders and from your country or jurisdiction
to other countries or jurisdictions around the world. If you or your end
users are located in the European Union or other regions with laws
governing data collection and use that may differ from U.S. law, please
note that you are transferring information and permitting the transfer
of information, including personal information, to a country and
jurisdiction that does not have the same data protection laws as your
jurisdiction. You consent to the transfer of your information to the
United States and the use and disclosure of information about you and
your end users, including personal information, as described in this
Privacy Policy.
Where we act as a controller under European data law, our lawful basis
for collecting and using the information described in this Privacy
Notice will depend on the information concerned and the specific context
in which we collect or use that information. We normally collect or use
information from you only where we have collected your consent to do so,
where we need the information to perform a contract with you, or where
the processing is in our legitimate interests and not overridden by your
data protection interests or fundamental rights and freedoms.
Specifically, when we:
use information to create or
manage an account, we need it in order to provide relevant services;
use contact information for
marketing purposes, we do so with your consent (which you can revoke
at any time); and
gather usage data and analyze it
to improve the Site, we do so based on our legitimate interest in
safeguarding and improving the Site.
If you have any questions or concerns about how information is
processed, including questions about how to exercise your rights as a
data subject, please contact us at the contact information provided in
this Privacy Notice.
Data Retention.
Subject to any mandatory obligations to delete data, your information
may be retained by us and in our Third-Party Agent portal, server logs,
databases and records. We will keep your information for no longer than
necessary for the purposes for which it is processed. Where there are
technical limitations that prevent deletion or anonymization, we will
safeguard and limit the use of information as required by applicable
law.
Your Employees.
Your acceptance of the terms of this Privacy Policy, in their entirety,
shall extend to your employees. You agree that any of your employees
that access your Account or visit the Site under the scope of their
employment with you agree to the terms of this Privacy Policy.
Security.
We endeavor to safeguard and protect our Account holders' information.
When Account holders submit personally identifiable information to the
Performance Marketing Partner Network, their personally identifiable information is
protected both online and offline. When our registration process asks
registrants to submit information such as bank account information
and/or credit card information (“Sensitive Information”), and when we
transmit such Sensitive Information, that Sensitive Information is
encrypted and protected. The Third-Party Agent servers that we utilize
to store personally identifiable information are kept in a secure
physical environment. The Third-Party Agent has security measures in
place to protect the loss, misuse and alteration of personally
identifiable information stored on its servers.
In compliance with applicable federal and state laws, we shall notify
you and any applicable regulatory agencies in the event that we learn of
an information security breach with respect to your personally
identifiable information. You will be notified via e-mail in the event
of such a breach. Please be advised that notice may be delayed in order
to address the needs of law enforcement, determine the scope of network
damage, and to engage in remedial measures.
You acknowledge that you provide your personally identifiable
information to us with knowledgeable consent and at your own risk.
Deleting and Updating Your Information.
If you would like to delete or update the personally identifiable
information that we have collected from you, simply email us. We will
process your request, where possible and subject to the terms and
conditions contained herein, within a reasonable period of time after
receipt. To protect your privacy and security, we will take reasonable
steps to help verify your identity before granting access or making
corrections.
Opting Out of Receiving E-mail.
You may at any time choose to stop receiving emails
containing general information regarding Three Spring Media by following the
instructions at the end of each such email or by contacting us. Should
you be contacted by our Third-Party Agent through email, you can follow
the instructions at the end of each such email to stop receiving such
emails. There may be a short delay of up to several business days while
your request is being verified, deployed and processed across our
servers. Notwithstanding the foregoing, we may continue to contact you
for the purpose of communicating information relating to your Account,
as well as to respond to any inquiry or request made by you.
Notification of Changes.
We reserve the right to change or update this Privacy Policy at any time
by posting a clear and conspicuous notice on the Site explaining that we
are changing our Privacy Policy. All Privacy Policy changes will take
effect immediately upon their posting on the Site. Please check the Site
periodically for any changes. Your continued use of the Site and/or
acceptance of our e-mail communications following the posting of changes
to this Privacy Policy will constitute your acceptance of any and all
changes.
Contact Us.
If you have any questions regarding this Privacy Policy, or would like
more information on our privacy practices, please contact us.