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CampaignDrive

Privacy Policy

Last Modified: April 5, 2019

Overview
Pica9 takes data privacy and data security very seriously. This privacy policy explains who we are and how we collect, share and use personal information. This policy also explains how you can exercise your privacy rights. We recommend you read this policy carefully.

Part 1 deals with visitors, Part 2 deals with users of Our Subscription Service.

For inquiries about this policy and how we collect and maintain your data, our full contact details are as follows:

Pica9 Inc.
Attention: Data Privacy Officer
10 East 38 th Street, 11 th Floor
New York, NY 10016

Our Data Privacy Officer can be reached at dataofficer@pica9.com.

Pica9 may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this page. All updates and amendments are effective immediately by posting a revised version of this privacy policy or other notice on our website. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically stored version of this privacy policy is deemed to be the true, complete, valid, authentic, and an enforceable copy of the privacy policy that was in effect on each respective date you visited our website.

Part 1

This section applies to the visitors to the Pica9 website and the personal Information we collect and process from each visitor in the usual course of business, including: advertising our products and services, offering information, and recruiting new Pica9 employees. In this Section, “you” and “your” refer to visitors.

A. Information Collected About You
(i) Information you provide to us on our website or otherwise.
Certain parts of our website may ask you to provide personal information voluntarily. For example, we may ask you to provide certain personal information (such as your name, contact details, company name, profile information) in order to:

(a) sign up as a user for our free trial
(b) sign up to receive marketing content or emails from Pica9
(c) apply for employment with Pica9
(d) or otherwise submit inquiries to us

We may also collect additional personal information in order to service our relationship with you, such as any additional details you submit to us when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.

The personal information that you are asked to provide will be made clear to you at the point we ask you to provide your personal information. We will also let you know prior to collection whether the provision of the personal information is required so that we have the relevant information in the context of the reason we are asking you to provide such information. We will inform you of the legitimate use of this information for the purpose expressly stated.

(ii) Information we collect automatically through our website
When you visit our website, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

As an example, we may automatically register your IP address, your operating system, your browser ID, your browsing activity, the content you consume and other information about your system and connection and how you interact with our website. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. A cookie is a small data file that certain Web sites write to your hard drive when you visit them. A cookie file can contain information, such as a user ID, that the site uses to track the pages you’ve visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites.

We receive and store certain types of information whenever you interact with us. We and our authorized agents automatically receive and record certain “traffic data” on our server logs from your browser including your IP address, cookie information, and the page you requested. We use this traffic data to help diagnose problems with its servers, analyze trends and administer the website. We may also use this data to better communicate with you based on your interests on our website.

We may use cookies to enhance the user experience and deliver personalized content. Cookies help us to deliver information specific to your interests and some parts of this site also may use cookies to track user traffic patterns for the purpose of determining the usefulness of information supplied to visitors, as well as see how effective our navigational structure is in helping users reach that information. We do not correlate this information with data about individual users, nor do we share this information or sell it to any third party. We may combine the information you provide us online with the technical information we receive to improve our knowledge of you as a potential customer and help us provide targeted products and services.

B. Use of personal Information
We may use the information we collect through our website for a range of reasons, including:

– To operate, improve or maintain our website
– To send you information for marketing and sales purposes, in accordance with your marketing preferences or sales requests
– For recruitment purposes if you have applied for a career opening with Pica9
– To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us
– To manage our website and system administration and security
– To improve the navigation and content of our website
– To identify any server problems or other IT or network issues
– To compile aggregated statistics about site usage and to better understand the preferences of our visitors
– To carry out research and development to improve our products and services
– To customize content and layout of our website
– To carry out other legitimate business purposes, as well as other lawful purposes

In addition, we may combine personal information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver content, a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine personal information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, personal information.

C. Public Information, Third-Party websites and vendors, Social Media
Our website includes social media features that allow you to post content from our website to various social media properties, such as LinkedIn, Twitter, and Facebook. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly.
Pica9 does not host these features, nor any personal information which you may submit to these social media platforms. Your use of these features is at your own risk without any expectation of privacy. Please be sure to review the privacy policies of such social media properties before using these features.

Links to third-party websites. Our website may reference third-party properties, containing hyperlinks that allow you to move to a different site. Each website may have privacy policies that differ from Pica9’s policies. We encourage you to carefully read the privacy policy of such website you visit.

Pica9 uses third-party technology and services to provide services to Pica9 to help identify, track and/or monitor your interactions with our website. In each case, when relevant and appropriate, according to data security laws, Pica9 has signed a Data Protection Agreement with such party acting as a Data Processor.

D. Other Data Protection Rights
You have the following data protection rights:

– To access, correct, update, or request deletion of your personal information. Pica9 takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your personal Information, or altering your data or marketing preferences by emailing us at dataofficer@pica9.com. We will consider your request in accordance with applicable laws.
– In addition, if you are a resident of the EEA, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by emailing us at dataofficer@pica9.com.
– Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal Information conducted in reliance on lawful processing grounds other than consent.
– You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

E. Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. In all cases, we only collect data for legitimate uses.

We will normally collect and use personal information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Usually, our legitimate interests typically include: improving, maintaining, providing and enhancing our technology, use of our free trial; ensuring the security of our website; and our marketing services activities.

If you are a user, we may need the personal information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not, as well as of the possible consequences if you do not provide your personal information.
Where required by law, we will collect personal information only where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at dataofficer@pica9.com.

F. International Transfers
Our servers are located in the United States or on Amazon’s Cloud Platform (AWS). Our offices are located in the United States. We may use vendors all over the world, in compliance with international export laws. All our offices operate under our standardized data security policies and use best efforts to keep your data safe.

G. Our Data Security
Pica9 takes commercially reasonable steps, both technical and organizationally in nature, to protect the personal information disclosed to Pica9 from misuse, loss, unauthorized access, disclosure, alteration and destruction. We use industry standard encryption methods for encrypting confidential data during transmission and storage, and use best practices to protect certificates (including, without limitation, annual certificate changes). Once a year, we use a third-party, independent, nationally recognized, US-certified public accountant with applicable knowledge and experience as our compliance auditor. This compliance auditor provides a SOC2 Statement of Compliance at least annually covering our processes and operations in general and in matters related to data security.

Part 2: Users of Our Subscription Service

Our customers use our Subscription Service (CampaignDrive or known as a name created by our customer) to build various marketing documents, some of which are webpages that people can visit to learn more about their business and some of which may include email information or mailing addresses for outbound marketing. Pica9 does not control the content of these webpages or outbound marketing documents or the types of information that our customers may choose to collect or manage using the subscription service. That information belongs to them and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy. Pica9 processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers, but we do not have control over its collection or management. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the subscription service, as permitted by this Privacy Policy, and as required by law. We have no direct relationship with individuals who provide personal Information to our customers. Pica9 acknowledges that you have the right to access your personal Information. Our customers control and are responsible for correcting, deleting or updating information they have collected from you using the subscription service. If requested to remove data, we will respond within a reasonable timeframe. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage. Our agreements with our customers prohibit them from using the subscription service to collect, manage, or process sensitive information. We are not responsible for our customers' use of information they collect on the subscription service.

Pica9 collects information under the direction of its customers and has no direct relationship with the individuals whose personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our subscription service, please contact the customer that you interact with directly. We may transfer personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.