1 - Information We Collect About Site Visitors

We may collect and combine information, which may include:

a. Contact Information that you provide to us through the Site: such as:

first and last name
email address
phone number
address
billing information
if you use the Site on behalf of an organization, the company name, industry and website URL

b. Log and Usage Information collected automatically through the Site: such as browser type you use, hardware model, operating system, IP address, unique device identifiers, access times, pages and content viewed, links clicked, and browsing behavior such as time spent, what site you came from, what site you visit when you leave us, browsing behavior, and whether you have opened our marketing emails or clicked links within them.

c. Communications: such as when you contact us with questions, requests or feedback.

d. Marketing data: such as your preferences for receiving communications about our or products, services, activities, and events, and details about how you engage with our communications.

e. Other information: if we collect any other information which is not specifically listed here, we will use it as described in this Privacy Notice or as otherwise described at the time of collection.

1 - Information We Collect About Site Visitors

We may collect and combine information, which may include:

a. Contact Information that you provide to us through the Site: such as:

first and last name
email address
phone number
address
billing information
if you use the Site on behalf of an organization, the company name, industry and website URL

b. Log and Usage Information collected automatically through the Site: such as browser type you use, hardware model, operating system, IP address, unique device identifiers, access times, pages and content viewed, links clicked, and browsing behavior such as time spent, what site you came from, what site you visit when you leave us, browsing behavior, and whether you have opened our marketing emails or clicked links within them.

c. Communications: such as when you contact us with questions, requests or feedback.

d. Marketing data: such as your preferences for receiving communications about our or products, services, activities, and events, and details about how you engage with our communications.

e. Other information: if we collect any other information which is not specifically listed here, we will use it as described in this Privacy Notice or as otherwise described at the time of collection.

2 - Business Contact Information

If you or your employer is: (i) a purchaser or licensee of, or (ii) a supplier or other business partner to, our Data Solutions, we collect the following:

a. Information related to your professional life: such as first and last name, company name, industry, website URL, username, password, email address and billing information.

b. Data Solutions customer or supplier relationship and account usage information: such as account activity, account usage, and billing and account administration information.

c. Content: such as content you view or interact with on the Site.

d. Communications: such as when we communicate with you (and vice versa) with questions, requests or feedback.

e. Marketing data: such as your preferences for receiving communications about our or our partners’ products, services, activities, and events, and details about how you engage with our communications.

f. Other information: if we collect any other information which is not specifically listed here, we will use it as described in this Privacy Notice or as otherwise described at the time of collection.

2 - Business Contact Information

If you or your employer is: (i) a purchaser or licensee of, or (ii) a supplier or other business partner to, our Data Solutions, we collect the following:

a. Information related to your professional life: such as first and last name, company name, industry, website URL, username, password, email address and billing information.

b. Data Solutions customer or supplier relationship and account usage information: such as account activity, account usage, and billing and account administration information.

c. Content: such as content you view or interact with on the Site.

d. Communications: such as when we communicate with you (and vice versa) with questions, requests or feedback.

e. Marketing data: such as your preferences for receiving communications about our or our partners’ products, services, activities, and events, and details about how you engage with our communications.

f. Other information: if we collect any other information which is not specifically listed here, we will use it as described in this Privacy Notice or as otherwise described at the time of collection.

3 - Sources of information

We collect information that you directly provide to us, such as when you submit a form, exchange emails or otherwise communicate with us, create an account, update your profile or send us a message with your information. We also receive automatically collected information as noted in Section 1(b) (Log and Usage Information collected automatically through the Site).

We may also receive information about you from:

exchanging business cards, meeting at industry meetings or client sessions etc.
public sources, such as social media platforms
our business partners, including but not limited to data services and marketing firms.

You may have the opportunity to refer friends or other contacts to us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

We may combine the above information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined information.

3 - Sources of information

We collect information that you directly provide to us, such as when you submit a form, exchange emails or otherwise communicate with us, create an account, update your profile or send us a message with your information. We also receive automatically collected information as noted in Section 1(b) (Log and Usage Information collected automatically through the Site).

We may also receive information about you from:

exchanging business cards, meeting at industry meetings or client sessions etc.
public sources, such as social media platforms
our business partners, including but not limited to data services and marketing firms.

You may have the opportunity to refer friends or other contacts to us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

We may combine the above information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined information.

4 - Tracking Technologies

We and our third party partners may collect some of the information noted in this Privacy Notice using cookies placed on your browser (to the extent that cookies are not restricted by the browser), pixel tags, web beacons, and HTTP headers (or other communication protocols) and the use of hashed email address. We may also use probabilistic IDs generated via the user agent string and IP address. These technologies are further defined below, and are used for authentication, to store your preferences or progress, and for advertising and analytics. To the extent such tracking technologies are subject to applicable legal requirements for us to provide you with a method to opt-out, we will provide such opt-out method on this Site.

Cookies: small text files stored on the User’s computer. Users can set their browser to reject cookies altogether, to reject our cookies in particular, or to delete cookies. However, this may cause some or all of our Site not to function on such user’s computer or device.

Pixel tags/web beacons: These are small blocks of code on a webpage which read and place cookies.

HTTP headers: These are transmitted whenever the Site is viewed, and contain technical information required to connect your browser to the webpage. This information may include information about the browser and the requested webpage. Predactiv collects this information.

4 - Tracking Technologies

We and our third party partners may collect some of the information noted in this Privacy Notice using cookies placed on your browser (to the extent that cookies are not restricted by the browser), pixel tags, web beacons, and HTTP headers (or other communication protocols) and the use of hashed email address. We may also use probabilistic IDs generated via the user agent string and IP address. These technologies are further defined below, and are used for authentication, to store your preferences or progress, and for advertising and analytics. To the extent such tracking technologies are subject to applicable legal requirements for us to provide you with a method to opt-out, we will provide such opt-out method on this Site.

Cookies: small text files stored on the User’s computer. Users can set their browser to reject cookies altogether, to reject our cookies in particular, or to delete cookies. However, this may cause some or all of our Site not to function on such user’s computer or device.

Pixel tags/web beacons: These are small blocks of code on a webpage which read and place cookies.

HTTP headers: These are transmitted whenever the Site is viewed, and contain technical information required to connect your browser to the webpage. This information may include information about the browser and the requested webpage. Predactiv collects this information.

5 - How We Use Your Information

We use information we collect about you to provide, maintain, and improve our Site and other interactions we have with you. For example, we use the information collected to:

Provide and deliver products and services and related communications, communicate with you within the context of our business relationship, and for billing and invoicing purposes.
Perform sales, marketing and product promotional purposes (e.g., uploading emails into LinkedIn and similar platforms to advertise new services to current and prospective customers).
Respond to your comments and questions and provide customer service.
Detect, investigate and prevent fraudulent transactions and other illegal activities, enforce and protect our rights, interests and property, and the rights, interests and property of others.
Comply with our legal and financial obligations.
Monitor and analyze trends, usage, and activities, and facilitate and improve our online experience.
Provide support for the Site and the Data Solutions and respond to your requests, questions and feedback.
Provide and allow our partners to provide advertising and marketing targeted toward your interests, subject to your choices as detailed in Section 7.
Customize and personalize your Site experience and the content that you see on the Site.

5 - How We Use Your Information

We use information we collect about you to provide, maintain, and improve our Site and other interactions we have with you. For example, we use the information collected to:

Provide and deliver products and services and related communications, communicate with you within the context of our business relationship, and for billing and invoicing purposes.
Perform sales, marketing and product promotional purposes (e.g., uploading emails into LinkedIn and similar platforms to advertise new services to current and prospective customers).
Respond to your comments and questions and provide customer service.
Detect, investigate and prevent fraudulent transactions and other illegal activities, enforce and protect our rights, interests and property, and the rights, interests and property of others.
Comply with our legal and financial obligations.
Monitor and analyze trends, usage, and activities, and facilitate and improve our online experience.
Provide support for the Site and the Data Solutions and respond to your requests, questions and feedback.
Provide and allow our partners to provide advertising and marketing targeted toward your interests, subject to your choices as detailed in Section 7.
Customize and personalize your Site experience and the content that you see on the Site.

6 - How We May Share Information

We may share your Personal Information in the following situations:

Third Party Providers. We may share data with service providers, vendors, contractors, or agents who complete transactions or perform services on our behalf, such as those that assist us with our business and internal operations like payment processing, fraud prevention, customer service, experiences, personalization, marketing, and advertising;

Affiliates. We may share data with our subsidiaries and affiliates, for purposes consistent with this Privacy Notice.

Change in Business. We may share data in connection with a corporate business transaction, such as a merger or acquisition of all or a portion of our business to another company, joint venture, corporate reorganization, insolvency or bankruptcy, financing, or sale of company assets;

To Comply with Law. We may share data to facilitate legal process, including to meet national security or law enforcement demands as permitted by law.

With Your Consent. We may share data with third parties when we have your consent.

Aggregated Information. We may use your information for research and development purposes, including to analyze and improve the Site and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from Personal Information (as defined in Section 11) that we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.

6 - How We May Share Information

We may share your Personal Information in the following situations:

Third Party Providers. We may share data with service providers, vendors, contractors, or agents who complete transactions or perform services on our behalf, such as those that assist us with our business and internal operations like payment processing, fraud prevention, customer service, experiences, personalization, marketing, and advertising;

Affiliates. We may share data with our subsidiaries and affiliates, for purposes consistent with this Privacy Notice.

Change in Business. We may share data in connection with a corporate business transaction, such as a merger or acquisition of all or a portion of our business to another company, joint venture, corporate reorganization, insolvency or bankruptcy, financing, or sale of company assets;

To Comply with Law. We may share data to facilitate legal process, including to meet national security or law enforcement demands as permitted by law.

With Your Consent. We may share data with third parties when we have your consent.

Aggregated Information. We may use your information for research and development purposes, including to analyze and improve the Site and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from Personal Information (as defined in Section 11) that we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.

7 - Your Choices.

We use advertising and analytics technologies to better understand your online activity on our Site and to provide, and/or have third party partners with whom we work provide, personalized products and services that may interest you. We may, and we may also allow third-party companies (including ad networks) to, serve advertisements, provide other advertising services and/or collect certain information when you visit our Site. We may, and third-party companies may, use pseudonymized personal data (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visit to this Site in order to provide advertisements about goods and services likely to be of interest to you, on this Site and others. To learn more about Interest-Based Advertising or to opt-out of this type of advertising, you can visit AboutAds.info/choices or NetworkAdvertising.org/choices, or (in Europe) the European Interactive Digital Advertising Alliance (“EDAA”) Opt-Out Site.

Some third-party companies may also use non-cookie technologies, such as statistical IDs. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques. If the third-party company uses non-cookie technologies for interest-based advertising, you can opt out using the methods listed at NetworkAdvertising.org/choices. Please note the industry opt outs only apply to use for interest-based advertising and may not apply to use for analytics or attribution.

Click below use the “Limit Ad-Tracking” function on this Site on mobile devices:

Instructions by Google for most Androids: Google Play Help

Instructions by Apple for iOS version 6 and above: Apple Support Center

Mobile environment:

While the opt-out methods described above often work for mobile web browsing, they are cookie-based and are therefore less reliable in mobile “app” environments that may not accept interest-based advertising cookies. Instead, you can typically opt out at the mobile platform level by the “limit ad tracking” function within the settings, as described below. Though we do not collect data from mobile apps for interest-based advertising, we or third parties we work with may use such data collected by others in delivering interest-based ads.

Most Android Users:

To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google here: Google Play Help.

Please note that this is a device setting and will disable interest-based ads from all providers, and not just for Predactiv.

iOS users: (version 6 and above)

To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple here: Apple Support Center.

Please note that this is a device setting and will disable interest-based ads from all providers, and not just for the Site.

Following an opt-out using the options offered by the Digital Advertising Alliance or the Network Advertising Initiative, you may still be shown advertisements by companies who participate in these programs, but such advertisements will be less relevant to your interests.

When you change your consents using our cookie consent tool on this Site, an opt-out cookie will be set on your browser which tells us that you have opted out. This means that the opt-out will only function if your browser is set to accept third party cookies. If your browser is set to automatically reject cookies or if you remove the opt-out cookie or all cookies from your browser, or change browsers, operating systems or devices, the opt-out mechanism will not work since we would not see an opt-out cookie on your browser.

Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

7 - Your Choices.

We use advertising and analytics technologies to better understand your online activity on our Site and to provide, and/or have third party partners with whom we work provide, personalized products and services that may interest you. We may, and we may also allow third-party companies (including ad networks) to, serve advertisements, provide other advertising services and/or collect certain information when you visit our Site. We may, and third-party companies may, use pseudonymized personal data (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visit to this Site in order to provide advertisements about goods and services likely to be of interest to you, on this Site and others. To learn more about Interest-Based Advertising or to opt-out of this type of advertising, you can visit AboutAds.info/choices or NetworkAdvertising.org/choices, or (in Europe) the European Interactive Digital Advertising Alliance (“EDAA”) Opt-Out Site.

Some third-party companies may also use non-cookie technologies, such as statistical IDs. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques. If the third-party company uses non-cookie technologies for interest-based advertising, you can opt out using the methods listed at NetworkAdvertising.org/choices. Please note the industry opt outs only apply to use for interest-based advertising and may not apply to use for analytics or attribution.

Click below use the “Limit Ad-Tracking” function on this Site on mobile devices:

Instructions by Google for most Androids: Google Play Help

Instructions by Apple for iOS version 6 and above: Apple Support Center

Mobile environment:

While the opt-out methods described above often work for mobile web browsing, they are cookie-based and are therefore less reliable in mobile “app” environments that may not accept interest-based advertising cookies. Instead, you can typically opt out at the mobile platform level by the “limit ad tracking” function within the settings, as described below. Though we do not collect data from mobile apps for interest-based advertising, we or third parties we work with may use such data collected by others in delivering interest-based ads.

Most Android Users:

To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google here: Google Play Help.

Please note that this is a device setting and will disable interest-based ads from all providers, and not just for Predactiv.

iOS users: (version 6 and above)

To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple here: Apple Support Center.

Please note that this is a device setting and will disable interest-based ads from all providers, and not just for the Site.

Following an opt-out using the options offered by the Digital Advertising Alliance or the Network Advertising Initiative, you may still be shown advertisements by companies who participate in these programs, but such advertisements will be less relevant to your interests.

When you change your consents using our cookie consent tool on this Site, an opt-out cookie will be set on your browser which tells us that you have opted out. This means that the opt-out will only function if your browser is set to accept third party cookies. If your browser is set to automatically reject cookies or if you remove the opt-out cookie or all cookies from your browser, or change browsers, operating systems or devices, the opt-out mechanism will not work since we would not see an opt-out cookie on your browser.

Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

8 - Google Analytics

We use Google Analytics, an analytics service provided by Google LLC. We use this service to help analyze how users use the Site, with a view to analyzing usage across devices and offering improvements for all users. To learn more about Google Analytics, please visit their Privacy Policy.

To opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on, please click here.

8 - Google Analytics

We use Google Analytics, an analytics service provided by Google LLC. We use this service to help analyze how users use the Site, with a view to analyzing usage across devices and offering improvements for all users. To learn more about Google Analytics, please visit their Privacy Policy.

To opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on, please click here.

9 - Data Security

We implement commercially reasonable security measures designed to protect your information. Despite our efforts, however, no security measures are completely impenetrable.

9 - Data Security

We implement commercially reasonable security measures designed to protect your information. Despite our efforts, however, no security measures are completely impenetrable.

10 - Data Retention

We store the information we collect about you for as long as necessary for the purpose(s) for which we collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. We may aggregate and anonymize data so that it can no longer be linked to a device or individual, therefore it ceases to be Personal Information or Personal Data (as defined in Sections 11 and 12 below respectively), and we may retain this data for longer periods.

10 - Data Retention

We store the information we collect about you for as long as necessary for the purpose(s) for which we collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. We may aggregate and anonymize data so that it can no longer be linked to a device or individual, therefore it ceases to be Personal Information or Personal Data (as defined in Sections 11 and 12 below respectively), and we may retain this data for longer periods.

11 - Supplemental Notice to Residents of California, Virginia, Colorado, Connecticut, Utah, Nevada and Other U.S. States in Which an Applicable Privacy Law is in Effect

11.1 Introduction.

In this section, we provide information for residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, and such other U.S. states in which an applicable privacy or data protection law is in effect from time to time, as may be required under the applicable privacy or data protection laws of such states in effect from time to time (“State Privacy Laws”). For instance, the California Consumer Privacy Act (“CCPA”), as amended by the California Consumer Privacy Rights Act (“CPRA”), and the Virginia Consumer Data Protection Act (“VCDPA”), require that we provide their respective residents certain specific information about how we handle their personal information. Because certain State Privacy Laws require that we disclose specific information about how we handle certain personal information collected about residents of their states, the scope of this section may be different than the scope of the rest of our Privacy Notice.

11.2 Definitions of key terms.

Under State Privacy Laws, subject to certain exceptions, “Personal Information” is generally any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household in the applicable state.

A “Sale” of Personal Information under State Privacy Laws such as CCPA and VCDPA may occur any time a business sells or makes available any Personal Information to a third party for monetary or other valuable consideration.

A “Share” of Personal Information under the CPRA generally means disclosing, making available or communicating Personal Information by a business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

“Cross-context behavioral advertising” means the targeting of advertising to a consumer based on the consumer’s Personal Information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.

“Sensitive personal information” under State Privacy Laws is generally defined as Personal Information that reveals sensitive information about a consumer, such as social security, driver’s license, state identification card or passport numbers, account log-in, financial account, debit card or credit card numbers in combination with any required security or access code, password or credentials allowing access to an account, precise geolocation, data revealing racial or ethnic origin, religious beliefs, physical or mental health diagnosis, sexual orientation, or citizen or immigrant status, as well as processing of genetic or biometric data for identification, and personal data collected from a known child.

11.3 Rights under State Privacy Laws.

Depending on where you reside, you may have additional legal rights with respect to your information under State Privacy Laws, beyond those described under Section 7 (Your Choices) above. These rights are described below. While some of these rights apply generally, certain rights apply in limited cases. Consistent with State Privacy Laws, this Supplemental Notice provides information about how to exercise such rights for residents of the above states. This section does not apply to any matters exempted from State Privacy Laws during the period of exemption, nor to matters covered by an applicable law prior to the relevant portion of the applicable State Privacy Laws going into effect.

Right to Know

You may have the right, depending on your jurisdiction, to request the following about the Personal Information we have collected about you during the past 12 months or other required time period*:

Provide and deliver products and services and related communications, communicate with you within the context of our business relationship, and for billing and invoicing purposes.

The categories and specific pieces of Personal Information we have collected about you;
The categories of sources from which we collected the Personal Information;
The business or commercial purpose for which we collected the Personal Information;
The categories of third parties to whom we Sold or with whom we Shared the Personal Information;
The categories of Personal Information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose;
The specific pieces of Personal Information about you that we collected, disclosed to third parties for a business purposes, Sold to and/or (if you reside in California) Shared with, third parties;
The right to receive requested information in a readily-usable format if provided electronically;
The right to update or correct any Personal Information which is out of date or incorrect.

*Note: Under some State Privacy Laws, the above right to know is limited to events that occurred in the preceding 12 months, while other State Privacy Laws may have a different time limitation or no time limitation.

11 - Supplemental Notice to Residents of California, Virginia, Colorado, Connecticut, Utah, Nevada and Other U.S. States in Which an Applicable Privacy Law is in Effect

11.1 Introduction.

In this section, we provide information for residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, and such other U.S. states in which an applicable privacy or data protection law is in effect from time to time, as may be required under the applicable privacy or data protection laws of such states in effect from time to time (“State Privacy Laws”). For instance, the California Consumer Privacy Act (“CCPA”), as amended by the California Consumer Privacy Rights Act (“CPRA”), and the Virginia Consumer Data Protection Act (“VCDPA”), require that we provide their respective residents certain specific information about how we handle their personal information. Because certain State Privacy Laws require that we disclose specific information about how we handle certain personal information collected about residents of their states, the scope of this section may be different than the scope of the rest of our Privacy Notice.

11.2 Definitions of key terms.

Under State Privacy Laws, subject to certain exceptions, “Personal Information” is generally any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household in the applicable state.

A “Sale” of Personal Information under State Privacy Laws such as CCPA and VCDPA may occur any time a business sells or makes available any Personal Information to a third party for monetary or other valuable consideration.

A “Share” of Personal Information under the CPRA generally means disclosing, making available or communicating Personal Information by a business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

“Cross-context behavioral advertising” means the targeting of advertising to a consumer based on the consumer’s Personal Information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.

“Sensitive personal information” under State Privacy Laws is generally defined as Personal Information that reveals sensitive information about a consumer, such as social security, driver’s license, state identification card or passport numbers, account log-in, financial account, debit card or credit card numbers in combination with any required security or access code, password or credentials allowing access to an account, precise geolocation, data revealing racial or ethnic origin, religious beliefs, physical or mental health diagnosis, sexual orientation, or citizen or immigrant status, as well as processing of genetic or biometric data for identification, and personal data collected from a known child.

11.3 Rights under State Privacy Laws.

Depending on where you reside, you may have additional legal rights with respect to your information under State Privacy Laws, beyond those described under Section 7 (Your Choices) above. These rights are described below. While some of these rights apply generally, certain rights apply in limited cases. Consistent with State Privacy Laws, this Supplemental Notice provides information about how to exercise such rights for residents of the above states. This section does not apply to any matters exempted from State Privacy Laws during the period of exemption, nor to matters covered by an applicable law prior to the relevant portion of the applicable State Privacy Laws going into effect.

Right to Know

You may have the right, depending on your jurisdiction, to request the following about the Personal Information we have collected about you during the past 12 months or other required time period*:

Provide and deliver products and services and related communications, communicate with you within the context of our business relationship, and for billing and invoicing purposes.

The categories and specific pieces of Personal Information we have collected about you;
The categories of sources from which we collected the Personal Information;
The business or commercial purpose for which we collected the Personal Information;
The categories of third parties to whom we Sold or with whom we Shared the Personal Information;
The categories of Personal Information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose;
The specific pieces of Personal Information about you that we collected, disclosed to third parties for a business purposes, Sold to and/or (if you reside in California) Shared with, third parties;
The right to receive requested information in a readily-usable format if provided electronically;
The right to update or correct any Personal Information which is out of date or incorrect.

*Note: Under some State Privacy Laws, the above right to know is limited to events that occurred in the preceding 12 months, while other State Privacy Laws may have a different time limitation or no time limitation.

Right of Deletion

You have the right to ask us to delete the Personal Information we have collected from you, subject to exceptions the law provides. For example, to the extent permitted by State Privacy Laws, we may deny a deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) protect our legal interests, to defend our rights in a case of potential, threatened, or actual litigation, and to enforce our rights; (e) comply with a legal obligation and/or (f) fulfill internal and lawful uses that are compatible with the context in which you provided the information.

Right of Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

Right to Opt-Out of Sales and/or Sharing of Personal Information

While Predactiv does not “sell” business contact information or data collected via our Site in the traditional sense of the word, in cases where we transfer Personal Information to third parties such as marketing partners, or in cases where or enable third parties to collect Personal Information from the Site (such as where third party tracking technologies are placed on the Site), this may constitute a “Sale” under certain State Privacy Laws (and/or a Sharing, with respect to Personal Information of California residents). Under certain State Privacy Laws, you have the right to opt of the Sales (and/or Sharing, if you reside in California) of your Personal Information to third parties. If we undertake any such activities in connection with Personal Information collected under this Privacy Notice, we will make a method available on our Site whereby you may opt-out of the Sales (and/or Sharing, for California Residents) of your Personal Information for such purposes.

Right to Limit Use & Disclosure of Sensitive Personal Information

We do not collect, use, or disclose information we believe to be sensitive under State Privacy Laws.

Notice at Collection

At or before the point of collection, notice must be provided to the individual of the categories of Personal Information collected and the purposes for which such information is used.

Exceptions to These Rights

The law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable.

Right to Appeal

You may appeal our decision with respect to a request you have submitted by emailing us at privacy@predactiv.com.

11.4 How to Exercise Your Rights.

If you reside in a relevant jurisdiction and would like to send us a request to exercise one of your above rights, you may do so by contacting us at privacy@predactiv.com on our Site or by calling us toll free at 1-800-272-1765.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To help protect your privacy and maintain security, we may take steps where required to verify your identity before granting you access to your Personal Information or complying with your request. We may not be able to respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11.5 Notice of Categories of Personal Information.

Certain terms used in this section have the meanings given to them in the CCPA, as amended by the CPRA. The information reflects our current practices, and our practices during the past 12 months. We collect the following categories of Personal Information, and may have collected any or all of this information in the past: (a) identifiers such as name, postal address, email address, account name; (b) categories described in the CCPA, such as telephone number, employment, bank, credit card number or other financial information; (c) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (d) internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement on the Site; (e) geolocation data; (f) professional or employment-related information; and (g) inferences drawn from any of the information identified above to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

11.6 Sources and Use of Personal Information.

We collect the Personal Information described in this Privacy Notice from the following sources:

Data customer or supplier entity directly
Visits to the Site
Advertising networks
Data analytics providers
Social networks
Our affiliates, subsidiaries and divisions
Data brokers.

We use Personal Information for the business and commercial purposes listed in Section 5 of this Privacy Notice.

11.7 Notice of Financial Incentives.

We may offer you a program, benefit or other offering related to the collection of Personal Information, which may be considered a financial incentive under applicable State Privacy Laws. If you wish to withdraw from the benefit, please contact us at the email or postal address listed in Section 19. We will not reduce the value of any incentive you previously received from us if you do so, or discriminate against you if you exercise such rights after signing up for the benefit. Each financial incentive related to submission and use of Personal Information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable State Privacy Laws. You will be notified of the Personal Information you are required to submit at the time you sign up for the incentive.

11.8 California “Shine the Light” law.

The California “Shine the Light” law requires some businesses to respond to requests from California customers about the disclosure of certain personal information to third parties for third party marketing purposes. Alternately, such businesses may adopt a policy of not disclosing such personal information to third parties for marketing purposes if a California customer has opted-out of such information sharing. We have adopted an opt-out policy. In order to opt-out, please contact us at the email or postal address listed in Section 19. In addition, see the instructions above regarding the Sale or Sharing of Personal Information.

Right of Deletion

You have the right to ask us to delete the Personal Information we have collected from you, subject to exceptions the law provides. For example, to the extent permitted by State Privacy Laws, we may deny a deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) protect our legal interests, to defend our rights in a case of potential, threatened, or actual litigation, and to enforce our rights; (e) comply with a legal obligation and/or (f) fulfill internal and lawful uses that are compatible with the context in which you provided the information.

Right of Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

Right to Opt-Out of Sales and/or Sharing of Personal Information

While Predactiv does not “sell” business contact information or data collected via our Site in the traditional sense of the word, in cases where we transfer Personal Information to third parties such as marketing partners, or in cases where or enable third parties to collect Personal Information from the Site (such as where third party tracking technologies are placed on the Site), this may constitute a “Sale” under certain State Privacy Laws (and/or a Sharing, with respect to Personal Information of California residents). Under certain State Privacy Laws, you have the right to opt of the Sales (and/or Sharing, if you reside in California) of your Personal Information to third parties. If we undertake any such activities in connection with Personal Information collected under this Privacy Notice, we will make a method available on our Site whereby you may opt-out of the Sales (and/or Sharing, for California Residents) of your Personal Information for such purposes.

Right to Limit Use & Disclosure of Sensitive Personal Information

We do not collect, use, or disclose information we believe to be sensitive under State Privacy Laws.

Notice at Collection

At or before the point of collection, notice must be provided to the individual of the categories of Personal Information collected and the purposes for which such information is used.

Exceptions to These Rights

The law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable.

Right to Appeal

You may appeal our decision with respect to a request you have submitted by emailing us at privacy@predactiv.com.

11.4 How to Exercise Your Rights.

If you reside in a relevant jurisdiction and would like to send us a request to exercise one of your above rights, you may do so by contacting us at privacy@predactiv.com on our Site or by calling us toll free at 1-800-272-1765.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To help protect your privacy and maintain security, we may take steps where required to verify your identity before granting you access to your Personal Information or complying with your request. We may not be able to respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11.5 Notice of Categories of Personal Information.

Certain terms used in this section have the meanings given to them in the CCPA, as amended by the CPRA. The information reflects our current practices, and our practices during the past 12 months. We collect the following categories of Personal Information, and may have collected any or all of this information in the past: (a) identifiers such as name, postal address, email address, account name; (b) categories described in the CCPA, such as telephone number, employment, bank, credit card number or other financial information; (c) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (d) internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement on the Site; (e) geolocation data; (f) professional or employment-related information; and (g) inferences drawn from any of the information identified above to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

11.6 Sources and Use of Personal Information.

We collect the Personal Information described in this Privacy Notice from the following sources:

Data customer or supplier entity directly
Visits to the Site
Advertising networks
Data analytics providers
Social networks
Our affiliates, subsidiaries and divisions
Data brokers.

We use Personal Information for the business and commercial purposes listed in Section 5 of this Privacy Notice.

11.7 Notice of Financial Incentives.

We may offer you a program, benefit or other offering related to the collection of Personal Information, which may be considered a financial incentive under applicable State Privacy Laws. If you wish to withdraw from the benefit, please contact us at the email or postal address listed in Section 19. We will not reduce the value of any incentive you previously received from us if you do so, or discriminate against you if you exercise such rights after signing up for the benefit. Each financial incentive related to submission and use of Personal Information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable State Privacy Laws. You will be notified of the Personal Information you are required to submit at the time you sign up for the incentive.

11.8 California “Shine the Light” law.

The California “Shine the Light” law requires some businesses to respond to requests from California customers about the disclosure of certain personal information to third parties for third party marketing purposes. Alternately, such businesses may adopt a policy of not disclosing such personal information to third parties for marketing purposes if a California customer has opted-out of such information sharing. We have adopted an opt-out policy. In order to opt-out, please contact us at the email or postal address listed in Section 19. In addition, see the instructions above regarding the Sale or Sharing of Personal Information.

12 - European Union, Switzerland and UK Data Subjects’ Privacy Rights

12.1 Individual rights.

If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) applies to our processing of your Personal Data. If you are located in Switzerland, The Swiss Federal Data Protection Act applies to our processing of Personal Data. If you are located in the United Kingdom, then the Data Protection Act 2018 applies to our processing of personal data (the foregoing laws in this sub-section, collectively, “EU Data Protection Laws”). To the extent information we collect is associated with an identified or identifiable natural person and is protected as personal data under EU Data Protection Laws, it is referred to in this Privacy Notice as “Personal Data”. These laws each grant those located respectively in the EEA, Switzerland, and the UK a set of clear privacy rights and imposes responsibilities on Predactiv as we process the Personal Data of data subjects located in those places (“EEA Data Subjects”). This section is designed to provide more information on how Predactiv adheres to the above EU Data Protection Laws and your rights as a data subject.

12.2 Data Subject Requests.

Subject to any exemptions provided by law, EEA Data Subjects have the right to request:

The right to be informed about the types of Personal Data being processed and the legal basis for processing;
the right to access and see the Personal Data being processed;
the right of rectification and to make corrections to Personal Data;
the right to erase Personal Data;
the right to restrict processing of Personal Data;
the right of data portability of Personal Data;
the right to object to the processing of Personal Data and
the right not to be subject to automated decision-making.

Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. As an example, the right to object applies to processing which is carried out on the basis of our legitimate interests and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. These rights may extend to the Personal Data we place into cookies or similar tracking technologies. Where processing is based on your consent, you may withdraw that consent at any time, although any processing previously carried out will still be legal. In order to exercise your data subjects’ rights or if you have any questions about these rights, you can write to us at privacy@predactiv.com. We will endeavor to respond to any requests to exercise your rights within one month from when they are made, although this period may be extended in some cases in which case we will inform you before the expiration of the one-month period. You also have the right to submit complaints to the supervisory authority in your jurisdiction. A list of supervisory authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

12.3 Cross-border transfers of EEA, Swiss and UK Personal Data:

We generally process data in the United States. When we share data through our Data Solutions, we provide data to companies globally. In each case, we have safeguards in place which allow those transfers to happen in a way that ensures data is handled in accordance with the applicable law. When we transfer Personal Data outside the EEA, Switzerland or UK, unless the recipient or location to which the data is transferred has been approved by the appropriate authorities as providing an adequate level of protection for personal data, we put in place measures to ensure that the transfer complies with the applicable EU Data Protection Law and that the Personal Data which is transferred is appropriately safeguarded. When we enter into business relationships which involves the transfer of Personal Data of EEA data subjects to the United States, we put in place reasonable transfer mechanisms, such as the EU standard contractual clauses with the recipient. More information about international data transfers under the GDPR can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en. If requested, we may make available a copy of such safeguards, as required by EU Data Protection Laws.

12.4 Data Protection Officer and Representative.

Predactiv has appointed a data protection officer to supervise our Personal Data processing-related activities, and to respond to requests as required.

Our DPO can be contacted as follows: Vincent Potier (Predactiv DPO), dpo@predactiv.com

Predactiv’s representative in the UK is: ShareThis UK Limited of 10 John Street, London WC1N 2EB, UK.

Predactiv’s representative in the EU is: Verasafe, representative@predactiv.com. If you have questions about your privacy rights, you may also send us an email at privacy@predactiv.com .

12.5 Legal Bases For Processing Personal Data.

We may process your Personal Data under applicable EU Data Protection Law on the following legal grounds:

Contractual Necessity: we may process your Personal Data to enter into or perform a contract with you.
Consent: where you have provided consent to process your Personal Data. You may withdraw your consent at any time.
Legitimate interest: we process your Personal Data to provide our Site to you, such as to provide our online user experience, communicate with you, provide customer service, market, analyze, operate and improve our business, and to protect our Site.
Where processing is necessary to comply with our legal obligations.

12.6 Onward Transfer/Data Privacy Framework.

Predactiv has certified that it adheres to the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF program principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies of this privacy policy and the above listed DPF program principles, the DPF program principles shall govern. To learn more about the DPF programs, and to view our certification page, please visit To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In the context of an onward transfer, Predactiv is responsible for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Predactiv shall remain liable under the DPF principles if its agent processes such personal data in a manner inconsistent with the DPF principles, unless the Predactiv proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Predactiv commits to resolve complaints about your privacy and our collecting or use of your personal information. European Union, UK, or Swiss individuals with inquiries or complaints regarding this privacy notice should first contact Predactiv directly at privacy@predactiv.com. We will respond to your complaint within 30 days of receipt.

For complaints that cannot be resolved between Predactiv and the individual concerned, Predactiv has further committed to refer unresolved privacy complaints under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to the BBB Data Privacy Framework Program, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you are an EU, UK or Swiss individual and you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint.

If your complaint is not satisfactorily addressed, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Other jurisdictions such as Switzerland and the UK may have similar panels and data protection regulators that may receive your complaint Predactiv agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.

Should your complaint remain fully or partially unresolved after a review by Predactiv, BBB Data Privacy Framework Program and the relevant DPA, you may be able to, under certain conditions, seek binding arbitration before the Data Privacy Framework Panel. For more information, please visit https://www.dataprivacyframework.gov/s/european-individuals.

The Federal Trade Commission has investigation and enforcement authority over our compliance with the Data Privacy Framework.

If you believe we have not respected your rights or otherwise not handled data correctly, then we encourage you to contact us directly and we will do everything possible to help.

However, where you still have a complaint, then you have the right to raise the matter with the Supervisory Authority (or data protection agency) in your country for resolution.

12 - European Union, Switzerland and UK Data Subjects’ Privacy Rights

12.1 Individual rights.

If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) applies to our processing of your Personal Data. If you are located in Switzerland, The Swiss Federal Data Protection Act applies to our processing of Personal Data. If you are located in the United Kingdom, then the Data Protection Act 2018 applies to our processing of personal data (the foregoing laws in this sub-section, collectively, “EU Data Protection Laws”). To the extent information we collect is associated with an identified or identifiable natural person and is protected as personal data under EU Data Protection Laws, it is referred to in this Privacy Notice as “Personal Data”. These laws each grant those located respectively in the EEA, Switzerland, and the UK a set of clear privacy rights and imposes responsibilities on Predactiv as we process the Personal Data of data subjects located in those places (“EEA Data Subjects”). This section is designed to provide more information on how Predactiv adheres to the above EU Data Protection Laws and your rights as a data subject.

12.2 Data Subject Requests.

Subject to any exemptions provided by law, EEA Data Subjects have the right to request:

The right to be informed about the types of Personal Data being processed and the legal basis for processing;
the right to access and see the Personal Data being processed;
the right of rectification and to make corrections to Personal Data;
the right to erase Personal Data;
the right to restrict processing of Personal Data;
the right of data portability of Personal Data;
the right to object to the processing of Personal Data and
the right not to be subject to automated decision-making.

Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. As an example, the right to object applies to processing which is carried out on the basis of our legitimate interests and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. These rights may extend to the Personal Data we place into cookies or similar tracking technologies. Where processing is based on your consent, you may withdraw that consent at any time, although any processing previously carried out will still be legal. In order to exercise your data subjects’ rights or if you have any questions about these rights, you can write to us at privacy@predactiv.com. We will endeavor to respond to any requests to exercise your rights within one month from when they are made, although this period may be extended in some cases in which case we will inform you before the expiration of the one-month period. You also have the right to submit complaints to the supervisory authority in your jurisdiction. A list of supervisory authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

12.3 Cross-border transfers of EEA, Swiss and UK Personal Data:

We generally process data in the United States. When we share data through our Data Solutions, we provide data to companies globally. In each case, we have safeguards in place which allow those transfers to happen in a way that ensures data is handled in accordance with the applicable law. When we transfer Personal Data outside the EEA, Switzerland or UK, unless the recipient or location to which the data is transferred has been approved by the appropriate authorities as providing an adequate level of protection for personal data, we put in place measures to ensure that the transfer complies with the applicable EU Data Protection Law and that the Personal Data which is transferred is appropriately safeguarded. When we enter into business relationships which involves the transfer of Personal Data of EEA data subjects to the United States, we put in place reasonable transfer mechanisms, such as the EU standard contractual clauses with the recipient. More information about international data transfers under the GDPR can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en. If requested, we may make available a copy of such safeguards, as required by EU Data Protection Laws.

12.4 Data Protection Officer and Representative.

Predactiv has appointed a data protection officer to supervise our Personal Data processing-related activities, and to respond to requests as required.

Our DPO can be contacted as follows: Vincent Potier (Predactiv DPO), dpo@predactiv.com

Predactiv’s representative in the UK is: ShareThis UK Limited of 10 John Street, London WC1N 2EB, UK.

Predactiv’s representative in the EU is: Verasafe, representative@predactiv.com. If you have questions about your privacy rights, you may also send us an email at privacy@predactiv.com .

12.5 Legal Bases For Processing Personal Data.

We may process your Personal Data under applicable EU Data Protection Law on the following legal grounds:

Contractual Necessity: we may process your Personal Data to enter into or perform a contract with you.
Consent: where you have provided consent to process your Personal Data. You may withdraw your consent at any time.
Legitimate interest: we process your Personal Data to provide our Site to you, such as to provide our online user experience, communicate with you, provide customer service, market, analyze, operate and improve our business, and to protect our Site.
Where processing is necessary to comply with our legal obligations.