adflow and Solutions Privacy Policy

Effective Date/Last Updated: October 8, 2024

For Residents of the United States and Canada Only. For Residents of the United Kingdom (“UK”), click here.

We (“we,” “our,” or “us”) provide the following Privacy Policy (“Privacy Policy” or “Policy”) and Notice at Collection, which describes how we collect, use, disclose, and share information that is personally-identifiable to a user (“Information”) from users of adflow and our “Solutions” services (collectively the “Services”) as described below. This Privacy Policy also discusses consumers’ data privacy rights under U.S. state law, including the California Consumer Privacy Act, as amended (“CCPA”) and other states that have adopted data privacy laws, and how to exercise those rights, and provides information to Canadian residents as required under the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial personal information protection laws. This Privacy Policy applies to all visitors and users of our Services that are integrated onto third-party partner websites, app and mobile-device applications (“Partner Sites”). Any undefined capitalized terms in this Privacy Policy shall have the same meaning as in our Terms and Conditions, which are fully incorporated herein by reference.

WHAT ARE ADFLOW AND SOLUTIONS AND WHAT SERVICES DO THEY PROVIDE?

adflow and Solutions, which are commonly owned by adflow Solutions, LLC or its affiliates, provide a suite of available advertising and related monetization solutions for media partners (“Partners”) which, in general contain offers for goods or services (“Offers”) which we source, and which are provided by third parties and our affiliates (“Advertisers”). The suite of Services currently includes: (i) the adflow solution, which involves serving an “Ad Modal” which contains a series of AI curated Offers to be displayed on Partner Sites, typically on the transaction confirmation page, (ii) the “Offer Gallery Solution” which provides an “Offer Gallery” of curated Offers to be displayed on Partner Sites, frequently as a mid-path on path sites, (iii) a “Customer Loyalty Solution” which uses the Ad Modal or the Offer Gallery to display Offers to power a Partner’s loyalty program and which typically involves the Partner awarding their customer loyalty program users redeemable points, tokens rewards or other currency (“Currency”) by completing Offers or taking other specified actions, and (iv) the Syndication Solution” in which a single Offer is placed on a Partner Site.

ACCEPTANCE OF PRIVACY POLICY

By accessing or using the Services, you signify your acceptance of this Privacy Policy and your agreement to the collection, use, disclosure, and sharing of your Information as described herein. If you do not intend to agree to the terms of this Privacy Policy, DO NOT access or use Services. You can opt-out of our Services here.

FOR U.S. AND CANADIAN RESIDENTS ONLY

If you are not a resident of the United States, Canada or the United Kingdom, you are not permitted to access or use Services. Please note that this Policy applies to residents of the United States who are age thirteen (13) years or older with parental consent or sixteen (16) years or older without parental consent and Canadian residents who are eighteen (18) and older. If you are a resident of the United Kingdom who is aged eighteen (18) or older, you are permitted to access the Services, but how we process your Information is governed by our UK Privacy Policy, which you should read and review prior to accessing or using the Services.

PRIVACY POLICY UPDATES

This Privacy Policy is subject to change from time to time. Your continued access or use of the Services 30 days following the posting of changes to these terms will confirm your acceptance of all changes made except for changes that expand or alter the use of your Information. If we expand or alter the use of your Information beyond what is described in this Privacy Policy, we will notify users by: (a) sending the modified Policy to our users via email; or (b) any other reasonable means acceptable under applicable state and federal law.

CATEGORIES OF INFORMATION WE COLLECT

We may collect the following categories of information:

Identifiers and related personal information (such as name, email and telephone number);
Information you provide to us through our various customer contact channels (such as your name, email address, phone number, and/or any other personal details you choose to provide when you contact us);
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);
Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses);
Information related to a user’s consent to receive SMS/text messaging and other forms of communication;
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends, and attitudes); and
Personal Information about you that we may obtain from third-party sources and platforms (including data validation services, authentication service providers, data enrichment providers, social networking sites, online marketing and segmentation providers and ad-targeting companies) to supplement the information we collect from Partners and Advertisers and directly from you. For example, when you sign up to an Offer using your email address, we verify with a validation service that the email address is real, in order to ensure valid registration information and prevent fraudulent signups. In other cases, we may use age verification providers in order to ensure that Offers are appropriate for a particular individual above or below the age of majority, or the age of digital consent.

HOW WE COLLECT INFORMATION

We may collect Information in the following ways:

From Partner Sites who may share Information with us such as identifiers and commercial information;
Directly from users based on their purchasing activity and any information provided via registration forms;
Via our hosting servers, which collect Information from users through various technological means when users access and interact with the Services;
From parties under our common control (which includes our parent, subsidiaries, and other entities under common control with us – collectively “Related Parties”) and from third parties from whom we license Information;
From third parties (including our service providers and contractors) who assist us in hosting and providing support for the Services;
From our Advertisers who advertise their goods and services through the Services;
From cookies (small text files placed on a user’s browser by a website that track online behavior), web beacons (single-pixel GIF image files), and other technological means (collectively, “Cookies”), and
By combining Information, collected from the sources described above.

HOW WE MAY USE INFORMATION

We may use Information in the following ways:

To provide you with Offers and other content that we believe may be of interest to you, including sending text/SMS message alerts and determining what Offers we show to you;
To communicate with you via email or other forms of communication that you have consented to receive;
For operation of our Services, content improvements, testing, research, analysis, and product development;
To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement, any inquiry specific to express written consent to receive text/SMS messages, and to demonstrate our compliance with applicable laws;
To validate the Information you provide to us and to detect, investigate, and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of the Terms and Conditions applicable to the Services, this Policy, or existing laws, rules, and regulations;
As necessary or appropriate to protect the rights, property, and/or safety of us and Partner Sites and our Advertisers, Related Parties, service providers, and any other third-party with whom we have a contractual relationship for commercial or business purposes;
To maintain suppression or opt-out lists so that we won’t contact users who have asked not to be contacted or be displayed one of our Service offerings;
To make our Services easier to use by eliminating the need for users to repeatedly enter their Information;
To augment Information by enhancing it with other data sources provided by third parties and Related Parties to enable us, for example, to gain deeper insights into our users;
To maintain appropriate legal or business records;
To enable us to conduct customer research and develop new services;
To verify your identity in relation to privacy requests you make; and
To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, or when we determine it is necessary to comply with applicable laws and/or regulations.

HOW WE MAY DISCLOSE AND/OR SHARE INFORMATION

We do not sell any Information. We may share Information with our Advertisers, Partners, service providers and Related Parties in the following ways and for the following purposes:

To enable our service providers to perform their respective tasks for business purposes such as verifying the accuracy of Information, and the delivery of text/SMS messaging and other forms of communication, provided that we have obtained consent from such users to be contacted by via text/SMS messaging and any other specific form of communication;
We may disclose your Information (including information you give us and Offer-related information you give to the Partner) to Partners when you engage with Offers while on the Partner’s site, including by swiping or clicking on Offers;
We disclose your Information (including email address and segmentation data (e.g. gender, age/DOB, postcode, title, phone number and third-party provided data), even where this information is not directly displayed on screen), to named Advertisers if you indicate that you wish to accept their Offers (including by swiping or clicking);
With our Related Parties to augment and verify the Information we collect and to develop and enhance their products and services; and
We may share information with our Customer Loyalty Solution Partners including transaction information such as a user taking actions that may entitle the user to Currency.

When we share Information with our service providers for business purposes, we enter into agreements that describe the purpose for which the Information is shared, restrict its use to the agreement’s specified purpose, and require that all Information remain confidential and be protected from unauthorized disclosure.

We may share Information with applicable third parties as necessary if we become the subject of bankruptcy proceedings, or in connection with the sale, assignment, merger, or other transfer of all or a portion of our business. If we are involved in any of these transactions, we will notify users via email (if we have been provided with that information) via or an updated Policy provided when experiencing the Services.

For the avoidance of doubt, SMS opt-in will not be shared with any third parties. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

MINORS

The Services are designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and other laws protecting children’s privacy. In compliance with COPPA, we do not knowingly collect or retain information from children under the age of 13. (If you are a parent or guardian of a child under 13 years of age and you think your child has given us Information, you can email us at help@myprivacyrequest.com.) In compliance with the CCPA, we do not knowingly sell or share Information of users under the age of 16.

We encourage parents and guardians to monitor the online activities of their children.

For Canadian residents, the Services are intended for use only by users who are 18 years of age or older.

COOKIES, INTEREST-BASED ADVERTISING, AND THIRD-PARTY ANALYTICS

The Services currently do not use Cookies (to find out more about Cookies, visit https://bit.ly/4e3YV4h). Some of our Advertisers and Partners may use Cookies so they can use Information gathered in this manner to recognize users across different channels and platforms, including computers, mobile devices, and Smart TVs. Our Advertisers and Partners may use this information over time for advertising, analytics, attribution, and reporting purposes.

We may use Google Analytics and similar tools provided by our third-party partners to help analyze how users interact with the Services and to display customized offers and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with the Services and do not involve the collection of any additional Information.

Most browsers are initially set up to accept Cookies, but users can reset their Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent or to refuse online tracking. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising. However, note that many websites do not honor or alter their behavior when a user has activated the “do-not-track” setting on their browser. The exception to this is in the case of California consumers, where companies who must comply with the CCPA must honor opt-out preference signals that consumers set on applicable browsers.

Even where a user rejects a Cookie, the user may still use a website but their ability to use certain features or offerings may be impaired. For example, if a user returns to a website that uses Cookies, the user may have to re-enter information that was previously provided on that same website. Many websites retain Cookie data indefinitely, unless a user exercises their data deletion rights under applicable data privacy laws.

Users may opt-out from interest-based advertising delivered to their web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms such as the Digital Adverting Alliance’s opt-out program located here or the National Advertising Institute’s opt-out program located here. Users may also choose to opt-out of interest-based advertising on their mobile devices. For more information, please click here.

Please note that opting out of interest-based advertising does not mean a user will no longer see advertising online. Rather, it means that the company or companies from which the user opts-out will no longer show offers that have been tailored to their interests.

OPTING-OUT FROM MARKETING

Users may opt-out from receiving future contact from us via the following ways:

Email Opt-Out. To opt-out from email marketing, click the unsubscribe link contained in the email or contact customer service, by clicking here.
SMS/Text Messaging Opt-Out. To revoke consent for, or opt-out from, SMS/text messaging, reply STOP to text/SMS messages received or contact customer service here.
Push Notification Opt-Out. To opt-out of browser-based push notifications, disable the notifications at the time you receive the notification or disable notifications through your browser’s settings.
Targeted Advertising Opt-Out. Although the Services do not use Cookies, you may opt-out of Cookies, interest-based advertising and/or third-party analytics on other websites by referencing the section above on Cookies, Interest-Based Advertising, and Third-Party Analytics. California consumers may also reference the Rights of California Consumers section on how to set their global privacy controls.
Ad Modal Opt-Out. To opt-out from being displayed the Ad Modal, please contact us at help@myprivacyrequest.com.

ACCESSING, CORRECTING, AND DELETING YOUR INFORMATION

Users may request that we provide additional information on how their Information has been processed or request that we correct or delete their Information by contacting us here. We will respond to user requests within forty-five (45) days. If a user requests deletion of their Information, please note that their Information will be suppressed from further use as described in this Policy. However, please remember that if we have shared a user’s information with our Advertisers and/or Partners, users will need to contact those Advertisers and/or Partners individually to have them suppress or delete their Information. Note that we may retain and use a user’s Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.

The rights to assess, correct and delete Information are mandated in some U.S. states and all Canadian provinces. U.S. consumers can learn more about their rights and how we respect them in the “U.S. State Law Rights and Disclosures” section below and Canadian consumers can learn more about their rights in the “Canadian Rights” section below.

When a request is made, we will ask individual users to identify themselves and the Information requested to be accessed, corrected, or deleted (suppressed) before processing such requests and, to the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on archive servers).

THIRD-PARTY SITES

The Services may contain links to other sites or services. When you link from a Service to a third-party site, you are leaving the Service and are subject to the privacy policies and terms and conditions of those sites – NOT this Privacy Policy. We are not responsible for the privacy practices, content, or security of such third-party sites.

SECURITY OF YOUR INFORMATION

We use commercially reasonable efforts to prevent unauthorized access, disclosure, or accidental loss or destruction of your Information. Access to your Information is strictly limited and we take reasonable measures to ensure that your Information is not accessible to the public. We restrict access to users’ Information to only those persons who need access to perform or provide their job or service, both internally and with our third-party service providers. Information we control is managed from our offices in New York, NY. We use industry standard encryption to help protect data in transit and at rest.

With the exception of gender, which we may collect in some cases, we do not otherwise generally collect Information considered to be sensitive personal information under privacy laws, such as medical information, health insurance information, data collected from an automated license plate recognition system, or Social Security Numbers.

While we have endeavored to create secure and reliable Services for users, we are not able to fully eliminate security risks associated with Information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit your Information will prevent your Information from being improperly accessed, stolen, or altered.

In compliance with applicable data privacy laws, we shall notify you and any applicable regulatory agencies if we learn of an information security breach of your Information. You will be notified via email 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.

U.S. STATE LAW RIGHTS AND DISCLOSURES

California was the first U.S. state to adopt a comprehensive data privacy law. Since the CCPA was adopted – and as of the date this Policy was last updated – about twenty states have enacted data privacy laws and more than a dozen states are currently considering adopting data privacy laws. All of these data privacy laws provide statutory rights to consumers in their state.

In general, the CCPA affords among the broadest range of rights to California consumers of the data privacy laws adopted to date. We currently offer all of our U.S. users the same rights afforded to California consumers. We also briefly describe any additional rights beyond those afforded under the CCPA in other states that have adopted data privacy laws.

The information below describes the rights afforded California consumers (as that term is defined in the CCPA) and how California consumers can exercise those rights. In general, the CCPA affords among the broadest range of rights to California consumers of the data privacy laws adopted to date. We currently offer all of our U.S. users the same rights afforded to California consumers. We also briefly describe any additional rights beyond those afforded under the CCPA in other states that have adopted data privacy laws.

NOTICE OF COLLECTION OF PERSONAL INFORMATION

This Policy provides timely notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the CCPA, that we collect Information at or before collection.

We do not sell Information. We may collect the following categories of Information from you and our Partner Sites and share them with Related Parties for commercial and business purposes and our service providers for business purposes:

Identifiers and related personal information (such as name, email and/or IP address and telephone number);
Commercial information (including preferences, products or services purchased, obtained, or considered, or other purchasing data);
Internet or similar network activity (such as browsing and search history and information about a consumer’s interaction with a website, application, or advertisement) and information made available via Internet activity (such as device types, user agent data, referring URLs, and IP addresses); and
Inferences drawn from other categories of Information (for example, a profile reflecting a person’s preferences, characteristics, psychological trends, and attitudes).

See CATEGORIES OF INFORMATION WE COLLECT for more information on the categories of Information we collect.

Depending on the nature of your interactions with the Services, we may use the above-described categories of Information for some or all of the business and commercial purposes described in the HOW WE USE INFORMATION and HOW WE MAY DISCLOSE AND/OR SHARE INFORMATION.

RIGHTS OF CALIFORNIA CONSUMERS

California consumers have rights under the CCPA regarding their Information. These rights are:

Right to Know. The right to know what Information we have collected, including the categories of Information, the source of collection, our purpose for collecting the Information, the categories of third parties with whom we disclose, share, or sell that Information and for what reason, and the specific pieces of Information we have collected about you.
Right to Delete. The right to request that we delete the Information about you that we have collected. Note that there are certain exceptions to this right, including when the Information is necessary to provide you with goods or services you requested, to prevent fraud, and to comply with our legal obligations.
Right to Correct. The right to request that we correct inaccurate Information that we maintain about you.
Right to Opt-Out of Sale/Sharing. The right to limit or opt-out from the sale or sharing of Information. Note that the adflow Services do not sell your Information with Advertisers and/or Partners.
Right to Opt-Out of Sale/Sharing of Sensitive Information. The right to limit or opt out from the sale or sharing of sensitive Information, as defined under the CCPA. Note that the adflow Services do not collect sensitive personal information or sell your Information, including any sensitive Information, to Advertisers and/or Partners.
Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising your privacy rights.

How to Exercise Your Rights

Although the Services do not sell Information with Advertisers or Partners, you may exercise any other statutory privacy rights by sending an email to help@myprivacyrequest.com.

Verification Process. We require a verification process for requests to access, correct or delete Information in order to prevent an unauthorized third party from accessing or making decisions regarding a user’s Information. Generally, we will verify a request by matching the identifying information supplied by the user with the Information we already have for the user. If we cannot verify the user using the foregoing method, we may request additional information, such as a government-issued identification card, which we will not retain or use for any other purpose. In most cases, we will facilitate your request through automated tools available through your password-protected account.

Use of an Authorized Agent. California consumers may also designate an authorized agent to make these requests on your behalf. You must provide written authorization to the authorized agent that they are authorized to act on your behalf. When contacting us, the agent must submit proof of that authorization. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued identification card, to verify your identity before processing your request to protect your Information.

Timing. We will confirm receipt of your request within ten (10) business days. For all verifiable consumer requests, we strive to respond within forty-five (45) days of receipt. If we require additional time, which can be up to ninety (90) days in the aggregate, we will provide written notice, including the reason for the delay. Any disclosures we provide will be delivered electronically in a secure fashion. If, for some reason, we cannot fulfill or comply with your request, our response will explain that decision.

If we have not taken action or deny your request to know, access, correct, delete or opt-out, you may appeal the decision within ninety (90) days by writing to us at help@myprivacyrequest.com. Within sixty (60) days of receipt of this written appeal, we will inform you in writing of any actions taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

How We Handle Deletion Requests After Verification. Once we receive and confirm your request to delete, we will delete or de-identify (and direct our service providers, vendors, and other applicable third parties to delete) your Information from our system other than from our archive servers (which we maintain for compliance purposes), unless there is an applicable exception. If we do not comply with a deletion request, we will provide you with grounds for the denial in writing. Note that after a deletion request, we may retain and use your Information for the limited purpose of complying with our policies, including this Policy and to comply with applicable laws.

Disclosure of Information Collected and Sold. Once we receive and confirm your verifiable consumer request to access your Information, we will disclose to you the following:

The categories and sources of Information collected;
Our business and commercial purposes for collecting that Information;
The categories of third parties with whom we shared that Information;
The specific pieces of Information collected;
We do not sell or share your Information with Advertisers and/or Partners for commercial purposes, but if we have shared it for any other purpose, we will disclose the categories of third parties with whom it was shared.

Notice of Right to Opt-Out of the Sale or Sharing of Your Information

California consumers have the statutory right to opt-out of the sale or sharing of their Information, including the sale or sharing of any Sensitive Information. The Services do not sell your Information to Advertisers or Partners. If you wish to opt-out of any sharing of your Information, you can send an email to help@myprivacyrequest.com and elect to opt-out from the sharing/sale of your Information.

Global Privacy Controls

Certain browsers allow users to enable an opt-out preference signal in their browser settings (a “Global Privacy Control”). When a Global Privacy Control is enabled, it signals websites that the user visits that the user is automatically exercising their right to opt-out of the sale or sharing of their Information without the need, for example, of clicking on a “Do Not Sell My Information” link.

Notice of Right to Limit Sensitive Personal Information

The CCPA defines “Sensitive Personal Information” as non-public information that reveals a consumer’s social security, driver’s license, state identification card, or passport number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, and Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. We do not collect Sensitive Personal Information as defined under the CCPA.

Commitment to Nondiscrimination. We are committed to not discriminating against California consumers who exercise their CCPA rights. As such, unless otherwise permitted by the CCPA, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not discriminate against users who exercise their rights, but please note that some of the functionality of the Websites may be unavailable if consumers exercise their right to have their Information deleted.

De-identified Data Disclosure. We may use de-identified data in some instances (data that cannot be linked to any identifiable natural person or any device linked to any such person). We maintain de-identified data without attempting to re-identify it, and any de-identified data that is sold or shared is not able to be re-identified.

Commitment to Nondiscrimination. We are committed to not discriminating against Virginia consumers who exercise their VCDPA rights. As such, unless otherwise permitted by the VCDPA, we will not deny, charge you different prices or rates, or provide a different quality level of goods or services, including through granting discounts or other benefits, or imposing penalties, and/or suggest that you may receive a different price, rate, or quality level of goods or services. While we do not discriminate against users who exercise their rights, please note that some of the functionality of the Website may be unavailable if consumers exercise their right to have their Information deleted.

RIGHTS OF RESIDENTS OF OTHER STATES THAT HAVE ADOPTED DATA PRIVACY LAWS

Each of the states that has adopted data privacy laws affords their residents data privacy rights with respect to the collection, use, sale and/or sharing of Information. As noted above, the CCPA affords California consumers a broad range of rights with respect to their Information and we have elected to afford all of our U.S. users with these rights. Some state data privacy laws afford consumers with other rights including the right to opt-out of targeted advertising and the right to opt-out of automated processing performed on Information that evaluates, analyzes, or predicts personal aspects of the user (“profiling”). If a user resident in a state that offers these rights requests that we afford users these state-specific rights, we will honor such requests.

Other states are expected to enact data privacy laws. We will update our privacy practices to comply with those laws when they’re effective.

DATA PROTECTION RIGHTS APPLICABLE TO CANADIAN USERS

Canadian users have certain data protection rights subject to applicable laws. For example, supported by a written request and proof of identification, you may consult what Information has been collected, used or shared, and/or ask that it be corrected. In addition, you may withdraw your consent to the collection, use, or sharing of your Information, including its sale. You may also be entitled to additional rights such as (i) the right to cease the dissemination of your personal information; (ii) the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization; (iii) the right to request that a hyperlink connecting your name to your Information be de-indexed; and (iv) the right to request that a hyperlink connecting your name to your Information be re-indexed. Although we would prefer that you contact us first, at any time you have to right to lodge a complaint with applicable data protection authorities.

Users who provide Information to us may contact us here to withdraw their consent, correct their Information and/or access what Information we have collected, used, and shared/sold. We will endeavor to respond to user requests within thirty (30) days. If you withdraw your consent and your Information is subsequently deleted, please note that your Information will be suppressed from further use as described in this Policy. However, please remember that if we have already shared your Information with our third-party Advertisers and/or Partners, you will need to contact those Advertisers and/or Partners individually to have them suppress or delete your Information. Note that we may retain and use your Information as necessary to comply with our policies including legal obligations, dispute resolution, and enforcement of our agreements.

When you make a request regarding accessing or correcting your Information, or to withdraw your consent, we will ask individual users to identify themselves and the Information requested to be accessed or corrected before processing such requests. To the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on archive servers).

QUESTIONS, SUGGESTIONS, OR TO CONTACT US

If you have any questions, comments, complaints, or suggestions regarding this Privacy Policy, please contact us here or email our Data Protection Officer at barskydpo@fluentco.com.