Last updated on July 31, 2017.
- The information we collect and how we collect it;
- What we do with the information we collect;
- How we share and disclose user information with third parties;
- TWM’s use of online analytics and tailored advertising;
- California Do-Not-Track disclosure requirements;
- How you can access and update your information;
- How we protect information;
- Linked sites and advertisements;
- Use of the Services by users from outside the United States;
- Use of the Services by children;
- How to contact us;
- Your California privacy rights;
- No rights of third parties; and
1. The information we collect and how we collect it.
How we collect and store information depends on the websites you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.
1.1 Information you provide
We may collect information about you during your use of the Services, including your name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, birth year, and information you provide or post on our Services or allow us to access when you do certain things, such as:
- Enter registration information for one or more of our Services;
- Enter a sweepstakes or contest or register for a promotion;
- Participate in voting or polling activities;
- Make a purchase;
- Request certain features (e.g., newsletters, updates, and other products);
- Sign up to receive SMS (text message) notifications;
- Download or use one of our mobile applications;
- Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS); or
- Post user-generated content, including comments, to or on any of our Services.
Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via a SNS, on message boards, chat areas or in advertising or notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties.
1.2 Automatically-collected information
1.2.1 Device/usage information
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.
1.2.2 Location information
We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Chicago, the Services may be customized with Chicago-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturers instructions for further details.
1.2.3 Cookies and other electronic technologies
When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) store your username and password; (b) analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above; (c) customize the Services to your preferences; and (d) control the advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. The cookies may reflect de-identified data linked to or derived from data you voluntarily have submitted to us, e.g., a hashed version of your email address that we may share with service providers, solely in non-human readable form. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browsers toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
1.3 Information from third parties
We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
1.4 Aggregate or de-identified data
2. What we do with the information we collect.
We use the information that we collect for the following purposes:
- For the purposes for which you provided it;
- To send you information about your relationship or transactions with us;
- To send you alerts or other communications via SMS messages or other media or networks;
- To notify you about new features of the Services, special events, or products, services, and special offers;
- To administer sweepstakes and contests;
- To process and respond to your inquiries;
- To contact you with information that we believe will be of interest to you;
- To attribute content that you make available through the Services;
- To generate and review reports and data about our user base and Service usage patterns;
- To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
- To improve the content and features of the Services or develop new Services;
- To allow us to personalize the content and advertising that you see on the Services and to understand how users interact with and use our advertisements and Services;
- To enforce the legal terms that govern your use of the Services;
- To administer and troubleshoot the Services; and
- To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites).
The Services are supported by advertising revenue. We will send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications.
3. How we share and disclose user information with third parties.
We will make your information available to other companies, websites, applications or people in the circumstances described below:
We may share your information with any agent or company that is part of TWM, Inc. in order to provide the Services or advertising or to communicate with you on our behalf.
When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors privacy policies or practices.
We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
We may share your information with third-parties with whom we have a contractual relationship, including without limitation third-party advertisers and advertising networks.
We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all TWM assets, or a financing or acquisition of all or a portion of our business by another company.
4. TWMs use of online analytics and tailored advertising.
4.1 Online analytics
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
4.2 Tailored advertising
When you use the Service, TWM may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that tailored ads may be delivered to you when you are using other websites. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g., user-generated content) for purposes of delivering tailored advertising on the Services and/or other websites.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. TWM also may use a third-party vendor, Flurry, to deliver advertisements on mobile applications or for mobile application analytics. You can exercise your choices related to Flurrys services here.
5. California Do-Not-Track disclosure requirements.
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, TRUSTes Advertising Choices page, the Google opt-out link, and Flurry opt-out information in Sections 4.1 and 4.2. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.
6. How you can access and update your information.
To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at support@TheWiseMarketer.com.
7. How we protect information.
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.
8. Linked sites and advertisements.
The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.
9. Use of the Services by users from outside the United States.
10. Use of the Services by children.
The Services are not intended for persons under the age of 13. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.
11. How to contact us.
12. Your California privacy rights.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to support@TheWiseMarketer.com.
13. No rights of third parties.