Privacy Policy Privacy Policy This Privacy Policy was last updated on April. 14, 2021 Digital Envoy is a trusted provider of IP geolocation, online authentication and related information to the Internet, entertainment, financial and marketing industries throughout the world. These services are delivered to the market via Digital Element and Digital Resolve, which are divisions of Digital Envoy. We apply our advanced, secure, data-driven technologies to our customers’ information to help them promote their businesses, serve their customers, and protect against fraud and cyber security threats. This policy applies to information collected by Digital Envoy as well as the products and services described below. You can learn more about Digital Envoy’s businesses on our website at www.digitalenvoy.com. We know privacy policies can sometimes be confusing and technical. To make this as easy as possible to read and understand, we have embedded links to definitions of key terms throughout the Policy. Our Commitment: Privacy by Design Digital Envoy is committed to the responsible use of Personal Information to help businesses make better decisions, secure their operations, and deliver personalized content while respecting personal privacy. To accomplish this goal, we adhere to Privacy by Design principles, taking personal privacy into consideration throughout the process of designing, building, and delivering information products and services. Personal Information Collection, Use, and Disclosure Digital Envoy may collect, use, and disclose Personal Information and other information described below when you visit our websites or in the course of providing our products and services. This Policy applies only to information collected through our sites and not to information collected offline or by other means. Data Collected On Our Websites In general, you can visit our websites without divulging any personal information about yourself or your organization. However, there are areas of the sites that do require certain personal information from you in order to complete their functions or provide you with a customized experience, and then we may need to know your name, company name, street address, email address, or telephone number. Certain portions of the site may not be available to those choosing not to reveal the information requested. On our websites and landing pages, we collect Personal Information only if you choose to give it to us, for example by inquiring about or registering for our services; subscribing to RSS feeds or blog posts; or electing to “follow” our associated business units (such as Digital Element, Digital Resolve, NetAcuity, Fraud Analyst, etc.) on social media sites. Please keep in mind that any comments or other information you post on our blogs or social media sites may be read, collected, and used by other readers. We automatically collect Log Data about your visits to our websites. This information does not identify you to us unless you have given us your name, contact information, or other identifying information. We use Personal Information and Log Data to respond to your requests, process transactions you initiate, improve our website, and deliver personalized content to you. We may disclose Log Data and Personal Information to third parties to help us in these activities (for example, to a service provider that sends email communications to you on our behalf), but we do not allow them to use it for other purposes. Our websites may include social media features such as the Facebook “Like” button. These features, which are either hosted by a third party or directly on our site, may collect your IP Address and the URL for the page you are visiting on our site. In order to function properly, the features may set a cookie. Your interactions with these features are governed by the privacy policy of the company that provides them. Information Digital Envoy Receives from Third Parties Digital Envoy may receive information about you from third parties. For example, our customers or partners may provide us with certain transaction information, which may include IP address and location information such as postal code and city. We do not obtain information such as name or email address from third parties. We may combine the information we receive from third parties with information we collect through our other data collection methods. If we do so and the resulting data enables us to identify an individual, Digital Envoy will treat the combined information as Personally Identifiable Information under this Privacy Policy. Data Collected and Used to Provide Digital Envoy Products and Services Marketing Services We provide a variety of data to our clients through our NetAcuity offerings. Customers may combine some or all features of our products and services described below. Digital Envoy’s division Digital Element does not build consumer profiles based on a specific person’s online behavior over time and across sites nor do we associate a consumer’s identity to any of our data. Digital Envoy’s division Digital Resolve does have products that allow clients to create user behavior profiles using personal information, but Digital Resolve does not have access to that personal data. These user profiles principally help Digital Resolve clients to prevent online fraud and identity theft. Customer Provided Data. We may receive and maintain on behalf of our customers certain information, referred to as customer relationship management data or CRM Data. Customer Relationship Management or “CRM” Data is the data and information associated with a company’s relationship with customers throughout the customer lifecycle. This information may include your IP address. CRM Data may reflect your online interactions with a particular advertiser, publisher, or retailer. Our customers acquire and use this data to provide you with targeted products or messaging, as well as to ensure they are obeying their legal obligations. This information belongs to our customers, not Digital Envoy, although we may use related anonymous data (such as general IP address traffic) to help us better understand Internet traffic patterns and to develop new products. Use of this information is governed by our customers’ respective privacy policy, and customers may disable any features which pass us IP address information. Digital Element’s Services. Digital Envoy division Digital Element provides NetAcuity IP Intelligence services that do not track individual behaviors or usage patterns, other than general knowledge of IP traffic at customer deployments of our NetAcuity servers, to the extent “Seen IPs” are activated by our customer. We collect IP Address and other location-related information using proprietary, patented technologies to map routable IP addresses worldwide. By augmenting our data with insights derived from select global service partners who obtain data on an opt-in basis in compliance with privacy laws, we provide city-level data down to the postal code level globally, and to the zip+4 level in the U.S. Our IP Intelligence services also use IP Address information to venues and organizations of interest, analyze website performance, detect potentially fraudulent transactions, identify malicious website traffic, target ads, and help our customers comply with geographic sales restrictions. Digital Element does not associate IP address information with individual names, email addresses or identities (and this information is not passed to us by customers or service partners) and we use efforts to aggregate and anonymize any data associated with IP addresses. Digital Element also provides a reverse geocoding solution that converts a device’s raw location coordinates into more useful geographic information. The solution also leverages an IP address along with the latitude/longitude information as a way to improve our geolocation service and to return information so we can provide a “mobility index factor” to tell clients if a device is connected to a mobile connection or a fixed connection. The information returned is not tied to a user’s personal information and is only available as to consumers who opt in to the service through our customer’s opt-in process. This reverse geocoding does not capture any device identifying data or information, such as email address, name, etc. Digital Resolve’s Services. Digital Envoy division Digital Resolve has a platform that provides multi-factor authentication, behavior monitoring, and digital identity screening services that leverage user behavior profiles comprised of IP Intelligence and other user information in order to prevent online fraud and identity theft. Digital Resolve’s platform allows clients to create profiles that may contain Personally Identifiable Information, but Digital Resolve is not privy to said information as that information is not passed to Digital Resolve’s service by the customer. Other Use and Disclosure of Personal Information Digital Envoy does not use or disclose Personal Information other than as described above, except: As a data processor, at the direction of our business customers, and in accordance with their own privacy policies; With your express permission; Where permitted by our customer agreements, for internal use, research, fraud prevention, and product development; To identify and respond to cyber security threats and to protect our rights and the rights of third parties; To (i) comply with US or foreign laws or to respond to lawful requests and legal process in US or foreign civil, criminal or investigative matters, (ii) enforce agreements, our terms and conditions, and policies, and protect our rights and property as the site owner, and (iii) in an emergency to protect the personal safety of Digital Envoy, its customers, or any person; To our customers to target content, products, advertisements, provide geotargeting or geo-restriction of content, or similar uses through IP address targeting; In an aggregated or de-identified form that does not directly identify you; With third party vendors, consultants and other service providers who are working on our behalf, but we limit their access and use of Personal Information to that which is needed to carry out their work for us; and In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company. Cookies, Advertising IDs and Other Technologies Website Cookies. We may use cookies, web beacons, pixel tags, Javascript, HTML5 local storage, or similar technologies, along with other information described in this policy to enhance and personalize your experience on our sites and to manage and enable preferences, transactions and related uses of Digital Envoy services and information. These technologies do not identify you to us unless you have voluntarily identified yourself on our websites. If you’ve set your browser to warn you before accepting cookies, you will receive a warning message with each cookie. You can refuse cookies by turning them off in your browser, but some of the features on our site may not work if you do. Various browsers may offer their own management tools for removing HTML5 local storage. To learn more about these technologies, click on the links provided. Third parties with whom we partner may use cookies, web beacons, pixel tags, Javascript, HTML5 local storage, or Flash LSOs to help us understand how visitors interact with our website or to deliver content, or to personalize ads you see online based on your visits to our website. We do not have access to or control of these third-party technologies. The information gathered by these technologies is not tied to Personal Information submitted on our website. You can use your browser settings to manage cookies. Various browsers may offer their own management tools for removing HTML5 local storage. To manage Flash LSOs, please click here. Analytics and Segmentation Cookies. We use cookies, web beacons, pixel tags and similar technologies in order to collect the information necessary to provide our analytics and marketing segmentation services described above. The contents of our cookies are encrypted and can’t be read without the encryption key. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file, or you may opt-out as described below. Our cookies do not tell our business customers who you are or where you live. Mobile Advertising IDs. We use Mobile Advertising IDs, also known as IDFA or IFA, and other marketing services. We obtain Mobile Advertising IDs from service partners or our SDK which have user consent to share this information. We utilize this data to create anonymous custom audience segments. These segments are never smaller than 100 records and never contain any personally identifiable information. You can find more information about how mobile advertising IDs are used and how to opt out of mobile advertising in our Transparency and Choice section below. Usage of Non-Identifying and De-Identified Information Non-identifying or de-identified information includes information collected from or about you that does not personally identify you. Digital Envoy treats IP addresses, log file information, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law requires us to do otherwise. Digital Envoy may use non-identifying or de-identified information for any purpose. To the extent that Digital Envoy combines non-identifying or de-identified information with your Personally Identifiable Information, Digital Envoy will treat the combined information as Personally Identifiable Information under this Privacy Policy. Usage of IP Addresses The Digital Envoy services use IP addresses to help organizations target users and detect and prevent fraudulent activity. Although Digital Envoy considers IP addresses to be non-identifying information, consistent with the laws of the United States, Digital Envoy recognizes that a number of regulators and courts in the European Union consider the IP addresses of data subjects of the European Union to be Personally Identifiable Information to the extent the IP address is able to identify a natural person. Digital Envoy will comply with laws applicable to it in the provision of its services to the extent the IP address is able to identify a natural person. Among other things, Digital Envoy obtains IP addresses and general location data through its GeoMPrint reverse geolocation service. Digital Envoy uses the location data from this data along with other data to create databases that pair IP addresses with the locations in which they are likely being used, down to a postal code level or latitude and longitude of resolution. Digital Envoy never obtains the user name, email address or other information that identifies the individual or natural person associated with the IP address. Sensitive Data We do not create audience segments based Sensitive Personal Information or on the precise real-time geographic-location of an individual derived through location-based services (e.g., GPS-enabled devices) without opt-in consent. Digital Envoy creates certain audience segments using our data science processing procedures based upon anonymous digital connection information associated with IP addresses or Mobile Advertising IDs, based on interactions we have seen with our customer web sites and apps. These segments do not include or reflect individual or even house-hold level behavior; rather, they are based on visits to customer web sites by IP addresses and historical location data, which is then modeled to apply to broader groups of people who we think are more or less likely to have similar preferences. Data Retention We retain information collected through our websites, email and phone communications for as long as your account is active or as needed to provide you services. We also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Upon request we will provide you with information about whether we hold any of your personal information. If you have an account with us, you may access, correct, or request deletion of your personal information by logging in to your account or by contacting us at privacy-team.digitalenvoy.com. We will respond to your request within a reasonable timeframe. We acknowledge that you have the right to access your personal information. Digital Envoy has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to privacy-team@digitalenvoy.com If requested to correct, amend or remove data we will respond within a reasonable timeframe. Transparency and Choice; Opt-Out Cookies. You can opt out of interest-based advertising served by companies that participate in the Digital Advertising Alliance’s Consumer Choice tool by visiting http://aboutads.info/choices. Mobile Advertising IDs Apple’s iOS IDFA can be reset by the user at any time. Users can opt out of all remarketing by enabling a device setting called “Limit Ad Tracking” (LAT), which restricts advertisers from using the IDFA for behavioral advertising. You can learn how to limit ad tracking on your iOS device or to reset your IDFA here: IDFA Opt-Out. Similar to IDFA for Apple devices, Android devices pass Google Advertising ID, which provides the same type of device-specific, unique, resettable ID for advertising as Apple IDFA or IFA. You can learn more about how identifiers on mobile are used for advertising and receive instruction for how to opt out of mobile advertising on the Google Privacy & Terms Please note that opting out does not mean you will block online advertising altogether or see fewer ads. It simply means that the ads that you see will not be personalized for you based upon your behavior tied to your Ad ID. Ads may be served because they relate to the website you are visiting or to your current search, or they may just be randomly placed. We comply with opt-out requests by placing an “opt-out cookie” on your computer or device. Consequently, if you clear your cookies on that computer or device, we will not be able to read our “opt-out cookie” and will resume collecting information from that computer or device for purposes of retargeting. Similarly, an opt-out request will not be effective on other browsers, computers, or devices you may use if you have not opted out while using that browser, computer, or device. Opt-Out of Database Sharing As discussed above in this Privacy Policy, Digital Envoy may share information we have about you in our databases with our customers and third parties (including but not limited to IP geolocation data we make available through the Services). If you want to opt-out of Digital Envoy sharing your database information with our customers and third parties, please send your request to privacy-team@digitalenvoy.com. This opt-out has several important qualifications: (a) You will only be able to opt-out to the extent that we can readily identify information we have about you. It is possible that even after you opt-out our databases will contain some residual information about you. (b) Other than as addressed in the preceding clause (a), Digital Envoy will cease sharing your information in any databases created after your opt-out date. Our customers may continue to have access to earlier legacy database information. (c) Even if you do opt-out of having us share the information we have about you in our databases, Digital Envoy may continue to gather, retain, use and share such information for fraud detection or legal compliance purposes. This is because your IP address may be associated with information that we have received from numerous customers. (d) If you opt-out based on your IP address, Digital Envoy will process the opt-out only if the IP address is associated with a single individual or household. Many IP addresses are shared by several if not hundreds of devices, and Digital Envoy cannot process an opt-out for shared IP addresses. Furthermore, since some IP address assignments are subject to change or are dynamic, Digital Envoy will only process an opt-out for sharing of information related to such an IP address until such time that Digital Envoy reasonably believes the IP address has been assigned to another device. However, in no event, will Digital Envoy remove such an opt out sooner than one year from such opt-out request. Security Digital Envoy has implemented policies and procedures that include reasonable administrative, technical, and physical safeguards designed to help protect Personal Information against unauthorized access, use, or disclosure. Notwithstanding the security precautions that we take, you should be aware that the transmission of information via the Internet is not completely secure. Because of this we cannot guarantee the security of Personal Information transmitted over the Internet. Children Digital Envoy does not knowingly collect information from children under 13, and we do not create marketing segments or knowingly enable advertising targeted to children under 18. Policy Changes This Policy may be changed from time to time by us, in which case we will revise the date at the beginning of this Policy setting forth when this Policy was last updated. We will post any Privacy Policy changes on this page and, if the changes are significant (also known as material changes), we will provide more prominent notice on this site prior to the changes becoming effective. Changes we determine to be material to this Policy will become effective 30 days after our posting such updates. Your California Privacy Rights California Do-Not-Track Disclosure. At this time, the Site is not set up to honor web browser do-not-track settings. When California customers provide Personally Identifiable Information to a business, they have the right to request certain disclosures if that business shares Personally Identifiable Information with third parties (and in some cases affiliates) for the third parties’ or affiliates’ direct marketing purposes. Once per calendar year the customer may request that the business provide at no charge a list of companies with which it shares Personally Identifiable Information for those companies’ direct marketing purposes, and a list of the categories of Personally Identifiable Information that the business shares. Instead of responding to such requests, however, a company may choose to comply with this law by establishing and publishing on its website a policy of not disclosing a customer’s Personally Identifiable Information to such third parties and affiliates unless the customer affirmatively agrees to such disclosures. Digital Envoy does not share Personally Identifiable Information as defined under California law with third parties or affiliates for those third parties’ or affiliates’ direct marketing purposes. California customers may request information about our compliance with this law by contacting us by e-mail at privacy-team@digitalenvoy.com or by mail at the address set forth in below. Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address. If you are a user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on our sites. You may send us any such requests by e-mail at privacy-team@digitalenvoy.com or by mail at the address set forth in below. We will review the request and respond promptly. You should be aware that a request to remove content or information posted by you on our sites does not ensure or require complete or comprehensive removal of such content or information from our databases. Disclosure for individuals in the European Union, the United Kingdom or Switzerland This is a United States-based website and is subject to United States law. Laws related to personal information and privacy vary by country. For example, Personal Data collected in the European Union is subject to the European Union General Data Protection Regulation (“GDPR”). To comply with the GDPR, we provide the following information, which is specific to individuals located in the European Union, the United Kingdom or Switzerland. “Personal Data” is defined by the GDPR and generally includes information that can be used to directly or indirectly identify an individual, such as names, addresses, cookie identifiers, mobile device identifiers and precise location data. A “controller” is an organization that processes Personal Data for its own purposes. The legal basis on which Digital Envoy, as a controller, processes your Personal Data will typically be: your consent, our legitimate interests, performance of a contract or compliance with legal obligations. To obtain your consent, we rely on our own compliance steps and the compliance steps of our data provider partners, which include data aggregators and SDK and App providers, designed to ensure that consent is collected and passed on to partners and recipients of the data, and to ensure that we only facilitate the collection of legally obtained data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed. We also rely on legitimate interest when we use our own customers’ data to communicate with them about our services or analyze our own website activity. You have the right to access, rectify, or erase any Personal Data we have collected about you through the services. You also have the right to data portability and the right to restrict or object to our processing of Personal Data we have collected about you through the services. To exercise your rights, contact us at privacy-team@digitalenvoy.com. However, please note that we are not always a controller of the Personal Data in our possession but sometimes we act as a processor for other companies (such as our customers). In such case, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data. Digital Envoy is certified under the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield framework regarding the collection, storage, transfer, use and other processing of Personal Data transferred to the United States from the European Union, the United Kingdom or Switzerland. Learn more by visiting our Privacy Shield Notice. Contact Us Digital Envoy Privacy 6525 The Corners Parkway NW Suite 400 Peachtree Corners, GA 30092 or privacy-team@digitalenvoy.com Definitions Cookies are text files placed on a computer’s browser that can be used to recognize you as a website user or to provide personalized content. Cross Device Linking is a technique used to predict or determine a likely association or relationship between two or more devices such as smartphones, tablets, desktop computers, etc. Customer Relationship Management or “CRM” Data is the data and information associated with a company’s relationship with customers throughout the customer lifecycle. The Domain Name System, or DNS, is the system that manages database tables that associate IP addresses with domain names such as digitalenvoy.com. Flash Cookies or Locally Shared Objects (LSOs) are messages used in Adobe Flash that are sent from a Web server to a Web browser and then stored as a data file in the browser. Flash cookies behave like conventional cookies by personalizing the user’s experience, but they can hold much more data than conventional cookies. Flash cookies may stay installed on a drive after ordinary cookies are deleted. IP Address Every device connected to the Internet is assigned a unique number known as an Internet protocol (IP) address. IP Addresses are assigned and reassigned by Internet Service Providers and companies regularly. ICANN is the Internet Corporation for Assigned Names and Numbers, which coordinates certain technical elements of the Domain Name System. Log Data is the Internet page request that is automatically collected when you visit a website, and typically includes the URL of the page requested, Internet Protocol address, browser type, browser language, mobile service provider, search terms, the date and time of your request, and information about one or more cookies that may uniquely identify your browser. Mobile Advertising IDs. Apple assigns an “ID for Advertising” (IDFA) to each iOS device, and Google assigns an “Advertising ID” to all Android devices. These anonymous IDs can be used to deliver ads and for advertising analytics in mobile applications. Apple’s iOS IDFA can be reset by the user at any time. Users can opt out of all remarketing by enabling a device setting called “Limit Ad Tracking” (LAT), which restricts advertisers from using the IDFA for behavioral advertising. You can learn how to limit ad tracking on your iOS device or to reset your IDFA here: IDFA Opt-Out. Similar to IDFA for Apple devices, Android devices pass Google Advertising ID, which provides the same type of device-specific, unique, resettable ID for advertising as Apple IDFA or IFA. You can learn more about how identifiers on mobile are used for advertising and receive instruction for how to opt out of mobile advertising on the Google Privacy & Terms Personal Information is information that personally identifies you, such as your name, email address or billing information, or other data that we can reasonably use to identify you. Pixel tags are placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and are often used in combination with cookies. Privacy by Design is an approach to protecting privacy in which privacy protections and considerations are embedded into the design specifications of technologies, business practices, and physical infrastructures. Sensitive Personal Information includes: Social Security Numbers or other Government-issued identifiers; insurance plan numbers; financial account numbers; information that describes the precise real-time geographic-location of an individual derived through location-based services such as through GPS-enabled devices; and precise information about past, present, or potential future health or medical conditions or treatments, including genetic, genomic, and family medical history. Uniform Resource Locators or “URLs” are web addresses consisting of a specific character string that constitutes a reference to an online resource. Most web browsers display the URL of a web page above the page in an address bar. A typical URL might look like: https://www.Digital Envoy.biz/privacy Web beacons or “clear Gifs” are small pieces of code placed on web pages that can be used for such purposes as counting visitors and delivering cookies or to otherwise customize the user experience. They contain a unique identifier that is used to track on-site activities of unique but unidentified website users. In contrast to cookies, which are stored on your computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. ©2021, Digital Envoy. All Rights Reserved. Privacy Policy | Privacy Shield