This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on rightandfree.com, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside rightandfree.com. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
LockerDome
Introduction
This Privacy and Cookie Policy (“Privacy Policy”) applies to data collected through LockerDome Inc. (“LockerDome“) websites, applications, widgets, and analytics tools hosted on lockerdome.com and third-party websites and applications (collectively, the “Service“). The Service is offered by LockerDome Inc., its subsidiaries and affiliated companies (collectively, “LockerDome,” or “we“, “us“, “our“).
This Privacy Policy is intended to help you better understand what data we collect, the ways in which this data is used, and steps you can take to update, manage, view, export and delete your data.
Please read this Privacy Policy in full and carefully. By accessing the Service, you are acknowledging that you understand and agree to the terms hereof as well as the Terms of Service.
Data We Collect
We use cookies, pixel tags, local storage objects, server logs and other tracking technologies to collect and store data about you and your activities. These tracking technologies carry unique identifiers, which are relative to either your browser or account, and allow us to make informed decisions to better your experience with our services, such as personalizing content and advertisements to match your taste profile, remembering your preferences, improving the features you use, and building new features and services.
We use both first- and third-party cookies. First-party cookies are set by the website that is being visited. Third-party cookies are set by a domain other than that of the website you are visiting. When accessing the Service on lockerdome.com, we set first-party cookies and our trusted third-party business partners set third-party cookies. When accessing the Service via a website we don’t own, we and our trusted third-party business partners set third-party cookies.
We use a combination of persistent and session cookies. Persistent cookies are cookies that remain on a user’s device for the period of time specified in the cookie; the length varies based on the use, but we typically expire persistent cookies within 18 months or less, although there are times we may need to keep them around for longer than 18 months. Session cookies are temporary, starting when your browser window opens and deleting when it closes.
Included in this Privacy Policy are options on how we collect and store your data through cookies. Further, you can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit or severely degrade your use of the Service.
Classifications of Cookies We Use.
Broadly, we use four classifications of cookies. Some of the cookies we use span multiple classifications.
Strictly Necessary Cookies
These cookies allow you to interact with the Service and access secure areas, such as updating your billing information. Without these cookies, we cannot provide the requested services in a useful and safe manner.
Performance Cookies
Allow us to analyze how users interact with the Service, so that we can improve the user experience and build new features that are useful.
Functionality Cookies
Used to remember choices you have made, such as layout, language or product preferences.
Targeting Cookies
Used to recommend content and advertisements that match your personal taste profile.
To inquire further about the specific cookies we use, please email us at privacy@lockerdome.com.
Basic Data We Automatically Collect.
When you access the Service, we collect and store basic device data, such as IP address, approximate geographic location, device type, browser, and operating system.
While this data alone is not considered personally identifiable, there are times where we take extra precautions to fully anonymize this data by truncating the IP address and obscuring other data that would allow someone to triangulate this data with other data sources to identify you. For example, we default to an anonymized approach (“Anonymous Mode”) if a user has explicitly requested to anonymize their data or if a user is physically located in the EU and has not provided explicit consent to collect, store and use personally identifiable data.
Activity.
Whenever you access the Service, we and our trusted third-party business partners, consisting of advertisers, publishers and third-party vendors (“Partners”), use a combination of the technologies listed above to better understand how you interact with our Services. This includes interactions with the Service directly, as well as tracking your activity when we directly refer you to a third-party website, such as tracking product purchases. This data is foundational in personalizing content and advertisements to match your taste profile, remembering your preferences, improving the features you use, and building new features and services.
Account and Profile Data.
When you register an account with LockerDome, we ask for personally identifiable data, such as name, email address, and date of birth. If you do not feel comfortable providing this data, please do not create an account. If you have already created an account and no longer feel comfortable with having provided this data, please follow the steps noted below under “Transparency and Choice” to update your data and settings, or delete your data and account, to match your personal comfort level.
If you are a publisher or advertiser, there is often additional data we need to collect in order to execute the business relationship, such as payment data; we collect, store and use this data directly through the Service, through and in conjunction with third-party vendors, and through various business forms, such as insertion orders. In all cases, this data is safeguarded and is only used for the sole purpose of executing the business relationship as contractually outlined.
How We Use the Data We Collect
We use data collected directly, from our trusted Partners, and via publicly available data sources to improve your experience with our services. For example, we use your activity data to better understand your personal preferences, ensuring we deliver you content, advertisements, and experiences that match your personal taste profile. More broadly, we analyze aggregated trends to better understand how our product decisions detract or add to your experience when accessing the Service.
Transparency and Choice
Our settings are designed to allow you to access the Service in a manner that aligns with your personal comfort level. Below are steps you can take to update, manage, view, export and delete your data.
Unregistered Users.
If you are accessing the Service as an unregistered user (e.g. you are not logged in), we still track the data described above in the “Basic Data We Automatically Collect” and “Activity” sections, but rather than tying that data to a logged-in account, we automatically associate it with a logged-out account ID, which allows us to personalize the content and advertising experience for you. If you do not want us to personalize the experience for you, please do one of the following:
Anonymizing Your Data
By choosing this option, you will begin accessing the Service in “Anonymous Mode,” in which we de-identify your data by truncating the IP address and obscuring other data that would allow someone to triangulate and identify you. Please note that to accomplish this, we will still be placing an opt-out cookie and a general account cookie on your device. The opt-out cookie instructs upfront to anonymize your data. By opting out, you will continue to receive content and ads, but they will be less relevant, as they will be blind to any data about you. The general account cookie allows us to obscure any data we do collect and store by pooling it with other data from the platform in a non-identifiable manner.
To ensure you are in Anonymous Mode in all places, you will need to opt out on each device and browser combination from which you access the Service. Further, whenever you switch to a new device or browser, or if you clear your cookies, you will need to opt out again to resume accessing the Service via Anonymous Mode.
Lastly, if you log in or create a new account, the Anonymous Mode status will no longer apply. Therefore, please do not create an account or log in if you wish to maintain accessing the Service via Anonymous Mode. Should you do this by accident, you can go through the opt-out process again from the device and browser from which you created an account or logged in.
Anonymous Mode
Deleting Your Data
To you delete your data, please fill out the form at the bottom of the page.
If you are currently using the Service in Anonymous Mode, the form will not be available, as we will not have any access to or knowledge of your personal data. For users located in the EU that have not explicitly provided consent to collect, store and use personally identifiable data, the form will also not be available.
To ensure we fully delete your data, you will need to make this request via each device and browser combination from which you accessed the Service.
Requesting Your Data
If you would like to request access to and/or export your data, please fill out the form at the bottom of the page.
Registered Users.
Updating or Correcting Your Data
If you are a registered user and would like to update or correct your data, go to “Profile Menu > Settings > Basic.”
Adjusting Your Settings
As a registered user, you can easily control settings like which social accounts are associated with your account and what kind of email communication you receive from us. To update these settings, go to “Profile Menu > Settings.”
Anonymizing Your Data
To completely anonymize your data, you will need to log out of your account, and then use the instructions above under “Unregistered Users > Anonymizing Your Data” to begin using the Service in Anonymous Mode.
Deleting Your Data
When logged in, you can easily update and delete most data and content you create. If you would like us to delete your account and all its personally identifiable data, please fill out the form at the bottom of the page.
Requesting Your Data
If you would like to request access to and/or export your data, please fill out the form at the bottom of the page.
Data Retention
Sometimes business and legal requirements require us to retain certain data, for specific purposes, for an extended period of time. Some of these reasons may include security, fraud and abuse prevention; financial reporting; complying with legal or regulatory requirements; and ensuring we can keep our systems operating as intended. In these cases, your data will remain safeguarded and will not be used to personalize your experience or shared in any manner not laid forth in this Privacy Policy.
Children
This Service is not intended for for children under the age of 13, or under the age limit (“Age Limit”) when it varies in other geographic regions. We do not knowingly collect personal data from children under the Age Limit. If we learn that we have collected personal data for a child under the Age Limit, we will take timely action to delete all personally identifiable data. If you are the parent of or know of a child that is under the Age Limit and has submitted personal data to the Service, please contact us immediately at privacy@lockerdome.com.
Safeguarding Your Data
We appreciate your trust and take the responsibility of securing your data seriously. To this end, we have established strict data standards and internal controls to ensure your data is always safe, including encrypting sensitive data and restricting data access to non-critical employees, among other security measures. These policies and protocols are reviewed regularly to ensure our game plan meets strict legal and internal standards.
When We Share Your Data
Publicly Available Content.
As a registered user, the content you create, as well as some of the non-sensitive personal data you enter about yourself (e.g. your name), is made publicly available. If you do not want this content and data available to others, please do not create or enter it. If you have previously created content or entered personal data and no longer want it publicly available, please log in and delete it. If you are also concerned about other personal data associated with your account, such as your activity, please follow the instructions above to request an account deletion.
Partners.
Our Partners independently collect and store their own data on users. In each of these cases, they are instructed to do so in full compliance with our Privacy Policy and other reasonable confidentiality and security measures. However, unless otherwise dictated by law or agreement, LockerDome is not responsible for any improper use by such parties.
Aggregated Trends.
We may analyze and disclose non-identifiable data, such as aggregated user trends, without restriction.
Legal.
We may disclose your data if we are required to do so by law.
Other Sites
The Service often contains links to third-party websites that we do not own or operate. Before clicking through content and accessing a third-party website, please visit the website’s Privacy Policy. Unless otherwise dictated by law or agreement, LockerDome is not responsible for any improper use by such parties.
California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personally identifiable data relating to third parties to which we have disclosed certain categories of personally identifiable data during the preceding year, for the third parties’ direct marketing purposes. To make such a request, please contact us at privacy@lockerdome.com.
Transferring Your Data
LockerDome is headquartered in the United States, and has operations, entities and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
Changes
On a periodic basis, changes will be made to Privacy Policy. Each time this happens, we will notify you of these changes, along with showing the effective date of the latest modifications. To ensure you are fully informed on these updates, please re-review this Privacy Policy on a regular basis.
Contact Us
For questions, comments and requests regarding this Privacy Policy, please email privacy@lockerdome.com or contact us by mail to LockerDome Inc., 1314 Washington Avenue, St. Louis, MO 63103, Attn: Legal Department.
PowerInbox
PowerInbox Privacy Policy
We (PowerInbox Inc. and/or PowerInbox Ltd. (collectively, “POWERINBOX”)) know that you care about how your information is used and shared, and we take your privacy seriously.
This POWERINBOX Privacy Policy covers our treatment of Personal Information (i.e., information which can be used to identify you), as well as other information we gather when you access any of our websites, including, but not limited to https://powerinbox.com/, http://rs-stripe.com/, and https://www.chameleos.com/ (collectively, the “Site”) or interact with our services, including AdServer for Email, RevenueStripe, InboxEngage, InboxChoice, and Advertiser Network (collectively, the Site and these services are the “Services”). We outline below the information collected by POWERINBOX through its Services, the purpose for collecting such information, who we share the information with, and choices that you may have with regard to your Personal Information.
The ways we use and share your information, including Personal Information, may vary depending on whether you are (i) a visitor to our Site (“Site Visitor”); (ii) a POWERINBOX customer (i.e., publisher, advertiser, or other content provider) (“Customer”); or (iii) recipients of emails from Customers (“Consumers”). We have therefore distinguished the information that relates to each of these types of individuals into three different sections below. Information that is relevant to all of these three categories is set forth in Section 1 of this Privacy Policy. Depending on how you interact with our Services, you may be part of more than one category (e.g., if you are a Customer who has also visited our Site, then Sections 1, 2, and 3 will apply to you).
For purposes of this Privacy Policy, we define “Personal Information” as personally identifiable information about an individual, such as a name and email address.
By visiting our Site, or by interacting with any of our Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.
GENERAL INFORMATION APPLICABLE TO SITE VISITORS, CUSTOMERS, AND CONSUMERS
As described in Sections 2-4 below, the information that we collect about you depends on whether you are a Site Visitor, Customer, or Consumer. We may also use or share your information in different ways. Regardless of whether you are a Site Visitor, Customer, or Consumer, however, we will use and share your information as follows:
HOW WE USE YOUR INFORMATION
Provide Our Services. We may use your information to provide and improve our Services and to develop new Services. For instance, if you are a Consumer we might process information about your broad geographic location in order to provide you with localized email content on behalf of our Customers, who incorporate our Services into their emails. We might also track your interaction with an advertisement that we serve on behalf of one of our Customers in an email.
Data Analytics. We may use your information to analyze use of our Services and understand how individuals engage with our Services. We do so at an aggregate level, in order to analyze general trends.
We may use your information to respond to your inquiries, fulfill your requests, complete your transactions, and for other service or support purposes.
Protection of POWERINBOX and Others. We may use your information to detect, prevent, investigate, and respond to potential fraud, security issues, or other threats to POWERINBOX or others.
Legal Compliance. We may use your information in order to comply with the law, regulation, subpoena, court order, or other legal process, or as part of an investigation or request from law enforcement or a government official.
In relation to Consumers, we convert email addresses into a random unique ID number, which we use in order to provide our Services to Customers over time (e.g., serving advertisements). Except for a limited period of time in server logs, we endeavor not to retain Consumer email addresses.
HOW WE SHARE YOUR INFORMATION
Service Providers.We may share your information with our vendors, service providers, agents, or others who perform functions on our behalf.
We may share your information with any current or future affiliates, parent companies, or subsidiaries.
We may share your information to comply with the law, regulation, subpoena, court order, or other legal process, or as part of an investigation or request from law enforcement or a government official or regulatory body.
Business Transfers. We may share your information with another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
Protection of POWERINBOX and Others. We may share your information to detect, prevent, or otherwise address fraud, security, or technical issues; to enforce the provisions of this Privacy Policy and/or any other agreements between you and POWERINBOX, including investigation of potential violations thereof; or to protect against harm to the rights, property, or safety of POWERINBOX, its visitors, users, and/or the public.
Aggregate or De-identified Data. We may share aggregate or de-identified data for marketing, advertising, research, compliance, or other purposes, mainly with respect to ad performance metrics and analytics.
THIRD-PARTY LINKS
Our Services may contain links to third-party websites and applications provided by third parties. Any access to and use of such linked websites, applications, or third-party services is not governed by this Privacy Policy but instead is governed by the privacy statements of those third parties. We are not responsible for the information practices of such third parties, and we encourage you to read their privacy statements.
SECURITY
We endeavor to take security measures to guard against unauthorized access to the systems where we store your information. This includes internal reviews of our data collection, storage, and processing practices and security measures and physical security measures. However, despite the measures we take, we cannot warrant the security of any information provided to us. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your information at any time.
DATA RETENTION
We will retain your information for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. When determining how long to retain your data, we consider: (i) the length of time we have an ongoing relationship with you as a Customer or, if you are a Consumer, what is reasonable and legitimate in the context of providing our Services (noting that we may retain de-identified information about your behavior in response to advertisements across successive Customer campaigns); (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our interests (e.g., to enforce any agreements between you and POWERINBOX or in light of regulator recommendations or industry best practices).
YOUR CHOICES
If you are a Site Visitor or Customer, you may verify, correct, or update the Personal Information we have about you by updating the Personal Information in your account (if you have one) or by emailing us at support@powerinbox.com. We may send periodic promotional or informational emails to Site Visitors and Customers, who may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. Site Visitors and Customers who opt out of receiving emails about recommendations or other information we think may interest them may still receive emails about their account or any Services they have requested or received from us.
If you are a Consumer, you should contact the Customer with whom you interact (i.e., the organization sending you emails that incorporate our technologies) in order to exercise any rights you might have to stop receiving those emails.
Users in certain countries have a right to communicate with their local supervisory authority / data protection regulator about our use of Personal Information.
CHILDREN
Our Services are not directed to individuals under the age of 13, and we do not knowingly collect any Personal Information from individuals under the age of 13. If you are the parent or guardian of an individual under the age of 13 and have a concern regarding the information we collect, please contact us at support@powerinbox.com.
POLICY CHANGES
This Privacy Policy is current as of the date set forth below. We may make changes to this Privacy Policy from time to time, so please be sure to check our Site back periodically. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Site or sending you an email.
CONTACT US
If you have feedback, questions, or concerns contact us at:
PowerInbox Inc.
311 W. 43rd Street, 12th Floor
New York, New York, 10036
(888)-824-8494
support@powerinbox.com
INFORMATION APPLICABLE TO SITE VISITORS
SITE VISITOR INFORMATIONWE COLLECT
Information You Provide. We collect any information that you enter on our Site, such as your name, user name, or email address.
When you visit our Site we will send your browser a cookie which is stored in your browser and allows us to uniquely identify it. The cookie may assist us in storing user preferences and product utilization information such as number of visitors, average time spent on pages, features used, and other information that helps us determine which features are most important to you and working effectively.
When you visit our Site, we capture and store the data that your browser sends us. This data may include your browser type, language, Internet Protocol address, the date and time of your request and the cookie that helps us identify your unique browser.
Usage Information. Generally, our Site automatically collects usage information, such as the numbers and frequency of visitors to our Site. We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of our Site or products so that we can improve our Services, products, and
Do Not Track Disclosure. Our Site does not respond to Do Not Track signals. You can learn more about Do Not Track signals at http://www.allaboutdnt.com/. You may, however, disable certain tracking by disabling cookies.
HOW WE USE SITE VISITOR INFORMATION
In addition to the purposes described above in Section 1.1, we may use your information:
To tailor the content and information that we display to you on our Site, and to otherwise personalize your experiences while using our Site; and
To provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes.
HOW WE SHARE SITE VISITOR INFORMATION
We share Site Visitor information as described above in Section 1.2.
INFORMATION APPLICABLE TO CUSTOMERS
CUSTOMER INFORMATIONWE COLLECT
Information You Provide. We collect any information that you provide to us, such as your name, user name, password, and contact information.
Information We Collect Automatically. We collect high-level metrics about the emails a Customer sends, including frequency of sends and volume.
HOW WE USE CUSTOMER INFORMATION
In addition to the purposes described above in Section 1.1, we may use your information:
To provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes.
HOW WE SHARE CUSTOMER INFORMATION
We share Customer information as described above in Section 1.2 and as follows:
Consumers. We may share Customer information with Consumers as part of providing our Services. For example, if you include your contact information in an email that is sent to Consumers through our Services, then that contact information will be shared with Consumers.
INFORMATION APPLICABLE TO CONSUMERS
CONSUMER INFORMATION WE COLLECT
Information You Provide. Unless you visit our Site or are a Customer, if you are a Consumer we do not collect any Personal Information from you directly. We do, however, collect information about you from Customers, such as your email address, in order to provide our Services. In the EU, we do not retain your name or email address (to the extent that we receive it from a Customer), and your email address is converted to a random unique internal ID number created by multiple levels of hashing so it cannot be identified.
Information We Collect Automatically. We automatically collect certain information about your activity through your interactions with messages sent using our Services, including when you open a message, when you click on an advertisement. We also collect and process your IP address.
HOW WE USE CONSUMER INFORMATION
In addition to the purposes described above in Section 1.1, we may use your information:
To tailor the content and information that we may send or display to you through our Services, and to otherwise personalize messages you receive through our Services.
To provide aggregated information to our Customers about how Consumers engage with their communications or advertisements.
HOW WE SHARE CONSUMER INFORMATION
We share Consumer information as described above in Section 1.2 and as follows:
POWERINBOX Customers.We share Consumer information with Customers. For example, we provide publishers with information about how Consumers view and click through to content and aggregate information numbers (e.g., traffic, revenue, etc.).
Version Date of this Privacy Policy: May 23, 2018