BOUNCEPILOT PRIVACY POLICY

Last updated: December 15, 2020

This Privacy Policy (“Policy”) describes how TowerData, Inc. (“BouncePilot”, “we,” “our,” or “us”) collects, uses, and retains your personal information when you visit our website (www.bouncepilot.com) (the “Site”) or in connection with the people-based marketing services (“Client Services”) we provide to our clients (“Clients”). We refer to the Site and the Client Services, together, as the “BouncePilot Services.” Please read this Policy carefully to understand your rights and choices over the data that we collect about you.

BouncePilot’s Services help our Clients, such as ecommerce companies, marketing companies, and online publishers, provide their customers and end-users (“End-Users”) with valuable content based on the End-Users’ interests, behaviors, and purchasing intentions. This Policy explains our data practices regarding the personally identifiable information we may collect about our Clients (“Client Data”) and the personally identifiable information we may collect about End-Users (“End-User Data”).

WHAT INFORMATION DO WE COLLECT?

Client Data

We collect certain Client Data when a Client visits our Site or purchases Client Services from us.

The categories of Client Data we may have collected about our Clients include:

  • Identifiers. Identifiers include data such as your full name, phone number, email address, or mailing address.
  • Internet and other electronic network activity, such as your browser type, IP address, referring URL, which pages you visit on our website, how long you browse our website, or whether you have opened an email we sent to you.
  • Geolocation information, such as your physical address, metropolitan area, or approximate physical location based on your IP address.
  • Professional and employment data, such as your occupation, title, employer, or industry.
  • Commercial information, such as the types of products or services you have purchased from us.
  • Payment information, such as credit card or bank account information.

Our Clients provide most of this information directly to us, such as when you communicate with us or place an order for Client Services. Some information, such as Internet and other electronic network activity data, is collected automatically via cookies, pixels, or web beacons on our Site or via the BouncePilot Services. You can learn more about our use of cookies in the Cookies section below.

End-User Data

We collect certain End-User data when End-Users interact with our Site or our Clients’ websites, digital properties, and businesses, or the digital properties of our business partners, including but not limited to the following:

  • Identifiers. We may collect identifiers such as your IP address, postal address, web browser or user agent, your hashed email address, or unique identifier assigned by one of our advertising partners (for example, a mobile advertising ID, such as Apple IDFA or Google AAID). In some cases, we may collect identifiers from different sources and link them together.
  • Internet and other electronic network activity, such as whether you opened an email, clicked on a link in an email, your device type, or your operating system and version. We also collect information about activity on our Clients’ websites, such as the time End-Users spend on a Client’s website, the pages an End-User visits, and the End-Users’ transactions.
  • Personal characteristics, such as your age or consumer interest segments.
  • Geolocation information, such as your zip code or metropolitan area, or an approximate location based on your IP address.
  • Inferences about your consumer preferences, such as the products you might be interested in purchasing or your income level.

We do not collect sensitive personal information, such as Social Security numbers, financial information, or medical information from End-Users.

Our Clients provide some End-User Data to us, such as through cookies and similar tracking technologies placed on our Clients’ digital properties. When a Client provides End-User Data to us, that End-User Data continues to be governed by our Client’s privacy policy. We encourage you to review the privacy policies of each website you visit.

We also obtain some End-User Data from third-party data brokers or partners (“Partners”), such as email addresses, mailing addresses, or demographics. We may link the End-User Data we already have about you with the data we obtain from our Clients or our Partners to create an End-User profile for individual End-Users.

HOW DO WE USE THE INFORMATION WE COLLECT?

We may use Client Data for the following purposes:

  • Providing the BouncePilot Services to our Site visitors and Clients and fulfilling our contractual obligations to them, such as providing information that a Client requests; delivering Client Services that a Client purchases; or sending Clients updates, notifications, and other administrative or account-related communications.
  • Improving and maintaining the BouncePilot Services, such as preparing for traffic load demands and distributing email publications; web analytics; analyzing and improving the performance, features, or functionality of the BouncePilot Services; direct marketing; or ensuring that the BouncePilot Services are secure and available.
  • When we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of our BouncePilot Services, or your safety or the safety of others; (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of terms of use related to the BouncePilot Services, or violations of law; or (c) to comply with legal processes or requirements, such as pursuant to judicial authorization.
  • For any other purposes if we have obtained your consent to such processing, for example, if you request a communication from us or affirmatively consent to additional processing.

We may use End-User Data for the following purposes:

  • Providing Client Services to our Clients, such as enabling our Clients to deliver personalized email or direct mail messages that match End-Users’ interests or behaviors (e.g., sending you an email if you leave the Client’s website while in the middle of a purchase transaction, often with a discount on that transaction); customizing End-Users’ user experiences when they use our Clients’ services; or helping our Clients understand their End-Users’ interests.
  • Improving and maintaining our Client Services, such as optimizing the features or functionality of the Client Services.
  • When we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of our Services, or your safety or the safety of others; (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of terms of use related to the Service, or violations of law; or (c) to comply with legal processes or requirements, such as pursuant to judicial authorization.

We may combine or aggregate any of the information we collect through our BouncePilot Services for any of these purposes.

HOW DO WE SHARE INFORMATION WE COLLECT?

We may disclose information we have collected to the following third parties:

  • Clients. We may share End-User Data, such as Identifiers (hashed email addresses, un-hashed email addresses, and postal addresses), Internet and other electronic network activity information, Personal characteristics, Geolocation information, and Inferences as part of the Client Services we provide to our Clients. We may also share de-identified, aggregated End-User Data with our Clients and other third parties.
  • Service providers, agents, and suppliers. We may share Client Data or End-User Data with our service providers, agents, and suppliers, who perform services for us to provide or operate the BouncePilot Services. Our service providers agree to privacy restrictions similar to the ones in our Privacy Policy by making similar commitments. These parties are not allowed to use Client Data or End-User Data except to provide services to us or on our behalf. For example, we use third-party service providers for email and direct mail campaigns, web analytics, marketing analytics, data storage, and cloud computing.
  • Affiliates, business partners, or other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, liquidation, bankruptcy, financing, or sale of all or a portion of our assets. We may share Client Data and End-User Data for that purpose.
  • Law enforcement or other governmental agencies. We may share Client Data and End-User Data with third parties when we reasonably believe disclosure is required or permitted in order to comply with a subpoena, court order or other applicable law, regulation or legal process.
  • Any other third party (a) when necessary to protect or secure the BouncePilot Services, our business, us, our Clients, or any other third party; (b) if we have aggregated and de-identified the information to make it available for purposes of research, reporting, or benchmarking; or (c) if we have obtained your consent to such sharing.

We may sell information to the following third parties:

  • Clients. We may sell End-User Data, such as Identifiers (hashed email addresses, un-hashed email addresses, and postal addresses), Internet and other electronic network activity information, Personal characteristics, Geolocation information, and Inferences as part of the Client Services we provide to our Clients.

YOUR DATA CHOICES

Unsubscribe and Opt-out

You can opt-out of the BouncePilot Services at any time by submitting an opt-out request at www.bouncepilot.com/opt-out/. To opt-out of third-party cookies, please go to http://www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Behavior-based Email

If you do not want us to serve you behavior-based email, you may opt-out here. You will need to opt-out for each email address you use. We will only use your email address, submitted in this way, for the purpose of suppressing emails which would have been directed to you. As you would expect, if you have directly opted-in to receive emails from other companies, you may still receive emails from them, but those will not be the behavior-based emails and discounts delivered through BouncePilot.

California Privacy Choices

California residents may have additional rights over their data. Please refer to the California Privacy Notice below.

COOKIES

To collect the information described above, we, our Clients, our Partners, or our service providers may use cookies, which are small text files that online services often store on computer hard drives or mobile devices of visitors to their sites. A cookie contains a unique number, which is used to recognize your computer when a user of your computer or mobile device returns to a website that it has visited previously. A website (for example, our Site, a Client’s website, or any other website that you visit) also may contain small, transparent images, files, or lines of code that collect information about how you interact with the pages, emails, advertisements, and apps. For example, these technologies may collect information about the web pages you visit, the content you view, when and for how long you interact with certain features, and whether you initiate a purchase transaction.

We may use these technologies to identify your computer or device (which can help us recognize you when you return), store information about your preferences (e.g., preferred language), log your interactions (e.g., the types of messages you prefer to receive), and present you with relevant interest-based or behavior-based email. We retain this information in a form that can identify your computer or device for up to 24 months.
Cookies help us personalize the BouncePilot Services and offer an effective and safe Site. We update our cookies periodically, but we generally use cookies for the following purposes:

  • To operate the Site. We use cookies for functions such as authentication, fraud prevention and detection, and site features and preferences.
  • To analyze and improve the BouncePilot Services. We use cookies to understand how you use the Site and other BouncePilot Services so that we can improve your user experience.
  • To provide you with more relevant advertising.
  • To deliver Client Services, such as helping our Clients understand your consumer preferences and deliver more relevant communications to you.

You can direct your browser to reject or delete cookies by adjusting your browser’s privacy settings. Please refer to your specific browser’s help menu to learn about how you can control the cookies we set in your browser.

SECURITY

We strive to maintain reasonable administrative, technical, and physical safeguards designed to safeguard the information we collect. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. We are not responsible for circumvention of any privacy settings or security measures we provide.

DATA RETENTION

In general, we retain your personal information according to applicable laws or regulatory requirements and keep it as long as is necessary to fulfill the purposes described in this Privacy Policy or for which the personal data was collected. If you have questions about the personal information that we retain about you, please contact us using the Contact Us information provided below.

Unless required by applicable law, we have no contractual obligation to retain your personal information for any specific length of time, although we may retain certain information to comply with our legal obligations.

CHILDREN’S PRIVACY

The BouncePilot Services are not intended for children under the age of 13 (“Children”), and we do not knowingly collect the personal information of Children. If you are a parent or guardian and believe we have collected information about any child, please contact us using the Contact Us information provided in this Privacy Policy. We will take steps to delete the information as soon as possible.

MODIFICATIONS TO THIS POLICY

We may update this Policy from time to time by posting an updated Policy on this page, and/or by providing any other notice or mechanism as required by applicable law. If you continue to access or use the BouncePilot Services after we have updated this Policy, you are acknowledging and agreeing to the revised Policy. We encourage you to check this page periodically for updates to our privacy practices.

CALIFORNIA PRIVACY NOTICE

This California Privacy Rights Notice (“Notice”) applies only to individuals residing in the State of California who are considered “consumers” and from whom we collect “personal information” as those terms are defined in the California Consumer Privacy Act of 2018 (“CCPA”). We will update this Notice at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes.

How We Collect, Use, and Disclose Your Data

In the last 12 months, we have collected the categories of personal information from the categories of sources listed in the “What Information Do We Collect?” section above. We have collected, used, or sold those categories of personal information for the business or commercial purposes specified in the “How Do We Use the Information We Collect?” section above. We may have disclosed, to the categories of third parties listed in “How Do We Share the Information We Collect?” section above, the following categories of personal information:

  • Identifiers
  • Internet or other electronic network activity information
  • Geolocation information
  • Personal characteristics
  • Commercial information
  • Professional and employment information
  • Payment information
  • Inferences

In the last 12 months, we have sold End-User Data, such as Identifiers (hashed email addresses, un-hashed email addresses, and postal addresses), Internet and other electronic network activity information, Personal characteristics, Geolocation information, and Inferences as part of the Client Services we provide to our Clients.

We do not knowingly sell the personal information of consumers under the age of 18.

Your CCPA Rights and Choice

California consumers have the following rights regarding our use and disclosure of your personal information, subject to certain limitations in the CCPA:

  • The right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
    • the categories of personal information we have collected about you;
    • the categories of sources from which we collected the personal information;
    • the business or commercial purpose(s) for collecting the personal information;
    • the categories of third parties with whom we shared the personal information;
    • the categories of personal information we have sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information.
  • The right to delete. You may request that we delete the personal information we have collected about you, subject to certain limitations under applicable law. We may be unable to delete all of your personal information if we need to retain your personal information:
    • To complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
    • To detect data security incidents;
    • To debug or repair any errors;
    • To protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
    • To use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).
  • The right to opt-out from a sale. Under the CCPA, you have a right to opt-out from the sale of your personal information. To exercise your right to opt-out, please submit a request here.
  • The right to non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

You may exercise any of the rights above by submitting a request using the Contact Us information provided below. We may need to verify your identity before responding to your request, such as by requesting government-issued identification or confirming your full name, email address or account access.

Authorized Agents

You may authorize someone to act as your agent and submit a CCPA request on your behalf. Before we will respond to any such request: (1) we require your agent to provide us with written evidence of permission to act on your behalf, and (2) you must verify your identity directly with us, unless your authorized agent is acting pursuant to a power of attorney under the California Probate Code.

Do Not Track

We are committed to providing you with meaningful choices about the information we collect on the BouncePilot Services, and that is why we provide the access and control choices set forth in this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track (“DNT”) signals, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, nor is there a consistent standard of interpreting user intent.

Your California Privacy Rights (Shine the Light Law)

Under Cal. Civ. Code § 1798.83, California residents have the right to request, once per year, information about whether we have disclosed your personal information to any third parties for their direct marketing purposes. To make a request, please send an email to peaceandlove@bouncepilot.com with the subject line “California Privacy Rights Request,” or mail your request to the address in the Contact Us section below.
We do not share your personal information with third parties for their direct marketing unless you have opted-in to third-party marketing. You can learn about how to opt-out of third-party marketing by following the instructions in the “Your Data Choices” section above.

THIRD PARTY DATA PRACTICES

We may provide content on the BouncePilot Services that links to third-party websites, content, products, or services. This Privacy Policy does not apply to third-party websites, content, products, or services, even if they link to or from our BouncePilot Services. We do not control, and are not responsible for, third parties’ privacy practices and content. When you visit a third-party website or use a third party’s products or services, the third party may collect your personal information, which will be governed by the third party’s privacy policy. Please read the third party’s privacy policy to learn about how they collect and process your personal information.

CONTACT US

We welcome your questions and feedback. If you have any questions or complaints about this Policy or our use of your information, please contact u:
By email at: peaceandlove@bouncepilot.com.
By mail at: BouncePilot Privacy
c/o TowerData
33 Irving Place, 3rd Floor
New York, NY 10002

THANK YOU, BOUNCEPILOT.