JU PITER DIGITAL MARKETING PRIVACY POLICY

Last Modified: July 19, 2019

INTRODUCTION:

Welcome to the Ju Piter Digital Marketing Ltd Privacy Policy (“Privacy Policy”). By visiting our Privacy Policy, you’ve taken the first step in educating yourself about advertising businesses such as ours that contribute to the Internet’s ability to remain largely an ecosystem of free content, as well as to provide a better user experience for consumers.

At Ju Piter Digital Marketing Ltd, or any of its subsidiaries, including ClickPros, a Jupiter Digital Marketing Ltd Website (“JupiterDM,” “we,” “us,” or “our”), we provide online advertising services. To do this, we follow information usage practices based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, JupiterDM creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.

If you have questions or concerns regarding this statement, please contact us by clicking here.

By visiting any JupiterDM website or mobile application, or any website or mobile application of one of its subsidiaries or affiliates (collectively, “Site” or “Sites”) or sharing any information with us, you agree to be bound by this Privacy Policy.

To start, it is important for you to know two definitions that are key to understanding our programs and privacy practices:

Personally Identifiable Information (“PII”): Information that can be linked to an identifiable individual person. This type of data includes things like full name, home address, telephone number, or email address.

Non-Personally Identifiable Information (“Non-PII”): Information that cannot identify an individual person, such as IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

Please take some time to read about what our business does, learn how we ensure that data you share with us is collected and used safely, and visit resources that provide more depth on our industry.

CONTENTS

Short Form Privacy Policy
Scope
What JupiterDM Does
Privacy by Design
Information Collection and Use
Use of the JupiterDM Sites as a Visitor or Client
Contact Us
Your Representations
Modifications to this Privacy Policy

SHORT FORM PRIVACY POLICY

We have included a table summarizing our practices solely for your convenience and reference purposes. This table is not an exhaustive description of our privacy practices and should not be construed to define, limit, and/or describe the scope or extent of this Privacy Policy. As a result, we urge you to read the entire Privacy Policy:

Information Collection: PIIWe do not collect PII except as expressly provided for herein. For example, PII may be collected should a consumer contact JupiterDM on his/her own initiative, register with a publisher to download a mobile app, or as part of our lead generation business.
Information Collection: Non-PIIThe Non-PII we collect may include, as an example, IP address, browser types, operating systems, domain names, platform type, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity.
How Information is UsedWe may use your Non-PII for purposes such as enhancement of our services, marketing, and to more effectively match advertisements, applications, and website content to your interests.
Sharing Your InformationWe may share your information with third party service providers with whom we have contracted, our subsidiaries and affiliates, third party marketing partners, business partners and our clients and publishers, and as expressly provided for herein.
Your ChoicesYou may regulate the collection and use of Non-PII via the opt-out options provided herein or by uninstalling or electing not to install a web browser or mobile application.
SecurityWe use reasonable and appropriate security measures to protect your data.
RetentionWe retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.
ChangesWe may change this Privacy Policy at any time by posting the revised Privacy Policy on the Site along with the date such Privacy Policy was last updated.
Contact UsIf you have any questions about this Privacy Policy, or the practices discussed herein, please contact us by clicking here.

SCOPE

This Privacy Policy is primarily intended to provide a description of the ways in which we collect and use information to deliver advertising across the Internet. For more on how we handle information collected from clients and publishers or visitors to our Sites, please see “Use of the JupiterDM Sites as a Visitor or Client” below.

Neither the Sites, nor our online activities or services for our clients, are directed toward or intended for children. We do not collect PII from any person of whom we have actual knowledge is under the age of 13. By using our website, the website of any of our publishers in our networks or submitting information to us, you consent to our use and sharing of the information collected or submitted as described in this Privacy Policy.

Please be aware that in addition to our Sites, the websites of our clients and publishers, applications on which we place advertisements and any third party websites linked to one of our Sites, may also collect information from you for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you. Such information collected by such websites and mobile applications and their affiliated or third party partners may include Non-PII through the use of cookies and other technologies. It may also include any PII you choose to provide in registering and transacting with such websites and mobile applications. Although we choose our business partners and clients carefully, JupiterDM is not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit to determine how they handle any information they collect from you.

WHAT JUPITERDM DOES

While you may only visit certain websites and mobile applications, there are other companies working behind the scenes to help provide you with a great digital experience. These third party companies provide vital services such as analytics, advertising and fraud prevention for retailers, publishers, and other organizations. These services enable these third party companies to, among other things, provide the advertising that keeps your favorite blogs free, your favorite stores in business, and your advertising experience more relevant.

We help companies provide digital advertising on browsers, mobile applications and televisions, and we do it in a variety of ways, from banner and video ads to coupon codes. To make some of these things possible, we need to utilize information to provide smarter decision making. Technologies such as cookies and mobile device IDs enable companies like ours to provide more relevant advertising while keeping your identity anonymous to JupiterDM.

PRIVACY BY DESIGN

Our philosophy on privacy follows the framework of Privacy by Design. We integrate privacy in strategy, product development, and more. We set the tone for privacy protection early and often, proactively working to keep PII out of JupiterDM’s systems, and building technologies that are effective without the use of PII. We can protect consumer privacy AND provide relevant advertising, which benefits everyone involved, especially advertisers, consumers, and small business websites and mobile applications. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance, and we are careful to protect privacy as data is collected, used, and destroyed responsibly.

We constantly strive to maintain unparalleled visibility with consumers. We provide transparency and choice through our website, encourage the same practice throughout the Internet.

INFORMATION COLLECTION AND USE

Information Collected by JupiterDM

JupiterDM only collects Non-PII from you (unless PII is provided by you voluntarily), and may collect this in a variety of ways. We may use technologies such as cookies, log files, pixel tags or other similar technologies to collect Non-PII about the browser or device you are using, including browsing activity, online transactions, and IP addresses. We may also receive similar Non-PII from third parties, which may additionally include the types of programming you view on your television. Some clients contribute PII such as your name, address, email address, and associated transactional information directly to a third party with whom JupiterDM has a contractual relationship. This third party removes the PII data points and provides JupiterDM only the Non-PII for our use in providing advertising to you. All Non-PII received and collected by JupiterDM from the various sources may be combined and used to provide you relevant advertising, and for other purposes as determined by JupiterDM.

We may also conduct surveys by serving interactive ads that ask you to provide information such as your gender and age range, which information may be associated with a device ID or a cookie ID. If you decide to respond, your demographic information will also be associated with a device ID or cookie ID and used only for the purposes described in this Privacy Policy.

“Cookies” are files that are stored on your web-enabled device and are used to improve your experience when seeing web and mobile advertisements. We may use cookies to estimate the total reach of an advertising campaign, as well as frequency of display, and to serve advertisements which are relevant to you. This allows advertisers to determine with greater accuracy the composition of the audience they reach and attempt to reach an audience that is interested in their products or services. There are many misconceptions about cookies. Cookies cannot erase your hard drive, install programs, or collect PII from your browser or device.

“Local Storage Data” are similar to cookies in that they allow data to be persisted in your browser when you visit a website. Local storage data are used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Information set in local storage data are only accessible from the same website domain that set the local storage data, and can only be set or accessed using JavaScript on pages from that same website. Local storage data have many of the same restrictions as cookies – if you delete cookies or your internet cache, local storage data are also deleted. Similarly, if you block cookies then local storage data are also blocked. Since local storage data are so similar to cookies and we treat local storage data with the same privacy and data protection principles as cookies, when we use the term “cookies” on this page or any other material on our website or elsewhere, we are including both cookies and local storage data.

“Device IDs” are unique identifiers associated with your mobile device to be used for advertising. These identifiers are assigned by your mobile device operating system, such as Apple’s iOS and Google’s Play Services for Android, and do not reveal your identity. Device IDs can be reset in your mobile device settings.

“Log files” track actions occurring on Sites and collect data including, as an example, your IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, click data and types of advertisements viewed.

“Web beacons” are objects that are embedded in a web page or e-mail and are usually invisible to the user but are used to track a web user’s navigation of a website or collection of websites or pages, interaction with an e-mail, use of mobile applications, the completion of transactions, submittal of applications and browsing behavior.

“Location Data” recognizes a consumer’s location while they are on their device which is utilized by JupiterDM to deliver advertisements. As with all data JupiterDM collects, this is limited to non-precise as defined by the Network Advertising Initiative’s current definition of imprecise location data unless the consumer has opted in to allow their precise location to be used.

The Non-PII collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match ads, mobile application and website content to your interests, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of JupiterDM’s services. JupiterDM may also act as a delivery agent when its products and services are used directly by a client to facilitate advertisements and other communications.

JupiterDM supports the NAI Code of Conduct’s obligations around the collection and use of health information for interest-based advertising (“IBA”).  This health-related information, when collected and/or used for relevant advertising, is non-sensitive and consumers may exercise choice through an opt-out basis.  The NAI also permits JupiterDM to collect and use sensitive health information when the user provides explicit opt-in consent in the United States. 

When a consumer responds to or views an Internet advertisement served by JupiterDM (such as through third-party websites or email solicitations) or visits a JupiterDM site, we may assign an anonymous, unique identifier to the end user’s Internet browser or device, often via a cookie. One function of these technologies is to provide JupiterDM with information for the purpose of paying third-parties affiliate commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser’s website. If the Internet user re-visits the advertiser’s site directly, JupiterDM is able to continue to track the user’s activities (excluding PII) on the advertiser’s site and credit the third-party website that referred the user. In other words, if a user reads a blog about a bicycle and decides to visit that advertiser’s website and purchase that bicycle, we would ensure that the blog gets compensated for referring the user to that advertiser’s website.

We also may use Internet browsing, cross-mobile application browsing and online purchase data associated with a user, on a Non-PII level, across multiple devices to develop a predictive statistical user profile of the end user’s needs and interests for the purpose of sending them relevant advertisements on multiple browsers and devices. This is called cross-device IBA. We may also use this cross-device functionality for the purpose of more accurately paying third-parties affiliate commissions, as described in the paragraph directly above.

Information Sharing by JupiterDM

JupiterDM will only share your information for limited purposes such as those provided in this Privacy Policy. This may include sharing information (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use and other agreements or to protect our rights ; (4) to protect the safety of members of the public and users of the service; (5) with JupiterDM affiliates and clients for marketing purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected partners for services including, but not limited to, data validation, enhancement, information verification and suppression services; or (7) for any other purpose for which you provide consent. None of this information will include PII except as provided herein. While JupiterDM strongly encourages clients and partners to adopt responsible approaches to online marketing, JupiterDM is not responsible for the information practices of such clients and partners. With respect to IBA, JupiterDM and other third parties may use Non-PII collected or shared with respect to your visits to websites with whom we have relationships for various purposes, including, but not limited to, providing advertisements about goods and services likely to be of greater interest to you.

In the event that JupiterDM is acquired by or merged with a third party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

Service-specific Provisions for Information Collection and Use:

Some products and services offered by JupiterDM have privacy considerations unique to those offerings. These considerations are covered here:

  • Lead Generation:

JupiterDM provides lead generation services to clients where we work with website publishers who utilize their display, search and email distribution channels to generate consumer interest or inquiry into advertiser products and services. The co-registration component refers to the process in which JupiterDM facilitates the exchange of consumer information (typically PII held by website publisher in accordance with their Privacy Policy) from website publishers to advertisers.

We may receive PII that our clients have collected in connection with our services for our clients or that clients have collected for access or transmittal purposes to other clients. We may hold such information and/or transmit or allow access to such information to the intended recipients or categories of recipients as requested by our clients.

As part of the Lead Gen services, online forms hosted by us, our clients, or third parties acting on the behalf of us or our clients may collect PII that a consumer has voluntarily provided. This information may be used for the same purposes listed in “Information Sharing by JupiterDM,” above. This information may also be used to verify any information submitted to use or any of our clients, and for any suppression or opt-out purposes.

JupiterDM may serve advertisements to you based, in part, on the demographic and geographic information you submitted to our clients during the website registration process, and lifestyle information about you that we obtain from them and other JupiterDM entities and third parties.

Security

The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure or destruction of data.

No transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your data, it may be possible for third parties not under the control of JupiterDM to unlawfully intercept or access transmissions or private communications. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. JupiterDM cannot ensure or warrant the security of information you transmit to us. You acknowledge and assume this risk when communicating with JupiterDM.

Retention

We retain online Non-PII for IBA for no more than eighteen (18) months. Aggregate reports generated from such data may be retained for a longer period, as ad delivery and reporting data.

USE OF THE JUPITERDM SITES AS A VISITOR OR CLIENT

You can browse the JupiterDM Sites without providing any PII. You may choose to provide PII to us voluntarily if you interact with our Site in certain ways, such as applying for employment with JupiterDM, responding to an advertisement for JupiterDM, or using one of our contact forms. This information is used only for the reasons it was collected, such as responding to your communication, and is not shared with third parties other than to fulfill the purpose for which it was collected.

JupiterDM may also collect Non-PII, through the use of technologies such as cookies, including IP address, browser type, operating system, domain name, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity. We may use this Non-PII for purposes including enhancement of our services, marketing, IBA, and to more effectively match website content to your interests. We may share your information with our third party service providers, JupiterDM and its subsidiaries and affiliates, third party marketing partners, our clients and publishers, and as expressly provided for herein.

We also use cookies to simplify login and to facilitate secure navigation through the password protected areas of the Site. Visitors who choose to reject all cookies may have difficulty navigating the password protected areas of the Site depending on the nature of their connection (dynamic IP, proxy server, etc.).

We may also partner with third parties who collect information on our Sites, and we may maintain links to other websites on our Sites. This Privacy Policy does not apply to the privacy practices of other websites or of third parties who collect information on our Sites. We would encourage you to visit the applicable policies of those third parties to see your opt-out choices from other participating companies that may be collecting and using data on JupiterDM’s websites.

For Clients and Publishers

The JupiterDM network includes our clients and publishers involved in advertising campaign transactions. Information collected from clients and publishers includes PII that is necessary to conduct business, such as name, phone number, and email address. Payments made to and from JupiterDM require the collection of PII that may include credit card numbers and bank account information. Phone numbers may be used for sales or inventory acquisition purposes. This information is collected, modified and stored in a password protected environment and is used for purposes including service, media delivery, contact, billing and accounts payable. We will not sell or rent this information to non-JupiterDM entities. All client and publisher information collected for these purposes is explicit, voluntary, manually entered, and can be opted-out.

Security:

See “Security” under Information Collection and Use, above.

Information Sharing:

This client and publisher information is not shared with any third party outside JupiterDM and its affiliated companies, except for that necessary to conduct business, such as clearing a credit card transaction for an advertising campaign purchase or making a direct deposit to pay a publisher, or as required by law. The security of this information is crucial to our success in the highly competitive field of online advertising. JupiterDM may, from time to time, use “gallery” pages to identify clients or publishers by business identity ONLY (e.g. Digital-Weaver.com is a new Publisher in the JupiterDM Network).

Log Files:

We record the IP address of new clients and publishers at sign-up. This can assist in administering the Site and client or publisher accounts, including features designed to enhance the Client experience. This information is part of the secure member database and is password protected.

Our Communications:

We send all new clients and publishers a welcoming email to verify password and user name, and may communicate with you about program or other information at the contact information you provide. We me also email individuals that have provided us with their contact info so that we can communicate information about JupiterDM’s services. You can request to opt out of these emails by filling out this form.

Site and Service Updates:

We may send Site and service announcement updates by email. Because these announcements contain important information about services, it is not possible to unsubscribe. We also communicate with clients and publishers to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating PII:

If a client’s or publisher’s PII changes (such as email address) or they would like PII removed from our system, we provide several ways to correct or update PII. The following options are provided:

Make the changes online by entering the member area.

Fill out a form by clicking here

Contact your account manager.

All requests to remove a client or publisher from our system will be verified prior to removal to ensure the proper identity of the requester.

CONTACT US

Have a question on something not addressed or have a complaint? Please use the Feedback form located here.

YOUR REPRESENTATIONS

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose information you supply to us with regard to: (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

MODIFICATIONS TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy. If we do, we will update the “Last Modified” date above. If we make a material change, such as the ways in which we use PII, we will notify you via a prominent notice on our Site.