Effective Date: February 17, 2021
Version2 is a digital marketing services agency which blends technology, data, inventory and strategy to provide targeted advertising services to our clients. Using information about consumers and their behavior online, Version2 is able to reach the audiences most likely to be interested in the products or services of Version2’s clients and facilitate the delivery of relevant, targeted advertising.
Applicability of this Privacy Notice
- Sharing of Information
- Data Transfer
- Your Privacy Choices
- Other Online Services and Third Party Features
- Retention of Personal Information
- California Privacy Rights
- European Union Privacy Notices
- Contacting Us
1. Information Collection and Use
Personal Information You Provide to Us through Our Site and Services. We collect personal information when you provide it through the use of the Site or Services, e.g., when you register to use the Service, when you post information on any interactive services or when you interact with us on social media. We also collect information that you provide by filling in forms on our website (including our “Contact” page), including requesting services or information about our products or requests that we contact you, and may retain records and copies of your correspondence (including email addresses) if you contact us, as well as details of transactions that you carry out with us and of the fulfillment of such transactions (including financial information). We also may collect personal information from you offline, such as when you contact us over the phone. Personal information that you provide to us may also include your name, address, company name, and telephone number. We may use the information you provide:
- To respond to your inquiries and fulfill your requests, such as to send you newsletters, updates, and e-mails, or to process payments, communicate with you regarding a purchase and provide you with related customer service;
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies;
- To send you marketing communications that we believe may be of interest to you; and
- To personalize your experience on the Site and Service by presenting products and offers tailored to you; and
- Other related business purposes.
Information We Collect by Automated Means.
Through Our Services: Version2’s advertising technology collects information about websites and applications that an Internet user interacts with and the advertisements that a browser or app displays. In providing our Services to clients, Version2 works with technology partners who process information collected from Internet users. Such technology partners are responsible for determining the legal basis for their processing of information if required under applicable law.
With our clients’ approval and at their direction, we place cookies or pixel tags on their website or app. The cookies or tags are bits of code that allow for our technology partners to collect information including your computer’s IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags. This information helps us learn about the Internet users who visit our clients’ websites and apps. It cannot be used by Version2 to identify a specific individual.
Version2 also receives demographic and other information from our technology partners that they collect from websites and mobile applications not controlled by our clients and which are visited by Internet users in groups that we are trying to reach on behalf of our clients. This information helps us to analyze trends and identify browsers of devices (collectively the audience) most likely to respond to an advertisement to the extent you consent to the use of advertising cookies on our client’s websites, and to help ensure that Internet users receive the most useful and relevant ads regardless of device or browser.
Please note that Version2 does not collect consumers’ names, email addresses, phone numbers or similar personally identifiable information through our Services and we do not link the information gathered by cookies or pixel tags to any personally identifiable information you may submit while on a website or in an app.
This information enables us to place advertisements onto the most relevant and cost-effective sites/app to achieve our clients’ marketing objectives while, at the same time, serve Internet users with advertisements that are relevant to their interests.
Through Our Own Site: We are committed to making your online experience with our Site informative and relevant. To achieve this, we collect information by automated means when you visit Version2’s Site, such as your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, clickstream data, referring URLs, your interactions with the Site (such as the web pages visited, links you click and features you use) and dates and times of Site visits. By collecting this information, we learn how to best tailor this Site to our visitors.
We collect information by various automated means on our Site, as explained below.
Cookies and Web Beacons.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons or pixels in emails to help us track response rates, identify when our emails are accessed or forwarded, and for other purposes listed below.
These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with the Site; (3) tailor the Site around your preferences; (4) measure the usability of the Site; (5) understand the effectiveness of our communications; and (6) otherwise manage and enhance the functionality of the Site.
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. You may adjust your cookie settings at any time by clicking here. Additionally, you can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.
Third-Party Web Analytics Services
2. Sharing Information
We may also share information collected by automated means via our Services with our clients after processing for reporting purposes. We may also share such information with our affiliates to perform analytics, or with our technology partners (such as data inventory providers and ad servers) to improve placements of advertisements and our Services.
In addition, we may disclose information about you as required by law, regulation of legal process (such as a court order or subpoena), in response to requests by law enforcement authorities or other government officials, to protect or defend our legal rights, or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, or violations for our Terms and Conditions for using this Site or other applicable policies. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business assets (including in the event of a reorganization dissolution or liquidation).
The security of information is important to us, and we maintain reasonable administrative, technical and organizational measures designed to protect the personal information we may collect. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or the information stored on our Site is absolutely secure.
Our Site and Services are not intended for children and we do not knowingly solicit personal data from or communicate with children under the age of 16. Further, this Site is not intended for incapacitated persons, and we do not knowingly solicit personal data from individuals who are incapacitated. If you become aware that your child, any child under your care, or a person otherwise not able to provide valid consent has provided us with information without a parent or guardian’s consent, please contact us using the contact information provided under “Contacting Us” below. If we become aware that a child under 16 or such other person has provided us with personal information without the appropriate parental or guardian consent, we will take steps to delete such information.
5. Data Transfer
We are located in the United States (“US”). We may transfer the personal information we collect about you to recipients (including our subsidiaries and affiliates, and third party service providers) in countries other than in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Policy.
If you are located in the European Union (“EU”) or other regions with laws governing data collection and use that may differ from the laws of the US, please note that you are transferring your information to the US, which does not have the same data protection laws as the EU.
6. Your Privacy Choices
If you wish to have access to information about you in our records, please contact us using the contact information in section 11 below. You may also request that we update information about you, or request correction of any factual errors that you believe may exist regarding this information. We will use commercially reasonable efforts to accommodate such requests. In any event, in no event will we be able to provide you with information about you that is not readily personally identifiable in our records or which would be prohibited by law. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
7. Other Online Services and Third-Party Features
The Site may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets and plug-ins (e.g., Instagram and Twitter buttons). These services, websites, and third-party features may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, Version2 is not responsible for these third parties’ information practices.
8. Retention of Personal Information
To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Policy, or (2) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data, such as complying with our legal and contractual obligations, resolving disputes, enforcing our agreements, or as is reasonably necessary for other business purposes.
9. California Privacy Rights
The California Consumer Privacy Act (“CCPA”) provides California consumers with certain rights regarding our collection of personal information from California consumers. If you are a California consumer, you have the following rights:
- The right to know what personal information is being collected about you.
- The right to know whether your personal information is sold or disclosed and to whom.
- The right to say no to the sale of personal information.
- The right to access your personal information.
- The right, in certain circumstances, to delete the information you have provided to us.
- The right to equal service and price, even if you exercise your privacy rights.
All consumer requests received under the CCPA will be treated and responded to in accordance with the CCPA and its implementing regulations. Accordingly, please understand that Version2 must first verify any request received prior to complying with any CCPA request.
Categories of Personal Information Collected: As further described above in this Policy, we may collect the following categories of personal information about you for the uses described in this Policy:
- Identifiers (e.g. name, email address, IP address, postal address, or other similar identifiers);
- Demographics / protected classifications (e.g. age, gender, race, or other protected classifications under applicable law);
- Professional or employment-related information;
- Education information;
- Commercial information (e.g. products or services purchased or other purchasing or consumption histories or tendencies);
- Geolocation data;
- Internet or other electronic network activity information (e.g. browsing history, search history, or information regarding your interaction with websites, applications or advertisements); and
- Inferences drawn from the information described above.
Requests for Information and Deletion. California consumers have the right to request, up to twice in a 12-month period, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months.
- (1) The categories of personal information it has collected about that consumer.
- (2) The categories of sources from which the personal information is collected.
- (3) The business or commercial purpose for collecting or selling personal information.
- (4) The categories of third parties with whom the business shares personal information.
- (5) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- (6) The categories of personal information that the business disclosed about the consumer for a business purpose.
- (7) The specific pieces of personal information it has collected about that consumer.
To make such a request for information, or to request that we delete your personal information, please email us at V2@theVersion2.com or contact us through our main website at https://theversion2.com/contact/.
No Sale of Personal Information: California consumers have the right to opt out of the sale of the consumer’s personal information. Version2 does not “sell” any “personal information” as that term is defined under CCPA. If you would like to receive further confirmation that Version2 does not and will not “sell” your personal information as that term is defined under CCPA, please email us at V2@theVersion2.com or contact us through our main website at https://theversion2.com/contact/.
Third Party Marketing. California Civil Code Section 1798.83 permits California consumers to request information regarding the disclosure of their personal information to third parties for the third parties’ direct marketing purposes in certain instances. If you are a California consumer and wish to make such a request, please contact us using the contact information provided in section 11.
10. European Union Privacy Notices
Privacy Rights. If you are located in the European Union, you may have the following rights:
- A right to lodge a complaint with the supervisory authority where we process your information in a way that does not comply with the laws and regulations.
- A right of access to information undergoing processing. We may charge a reasonable administrative fee if further copies of your information are requested.
- A right to rectify inaccuracies in information we collect and hold about you.
- A right to require your information to be provided to you or to another company in a commonly used electronic form.
- A right to object to specific types of processing such as direct marketing, processing based on legitimate interest, or processing for research or statistical purposes.
- A right to have your information ‘erased.’
- A right to temporarily restrict processing of information, for example if you believe the information is inaccurate or being used illegally.
- A right to withdraw your consent for future processing.
If you want to exercise or request more information about one or more of the above rights, you can contact us using the contact information listed in Section 11.
Legal Bases for Processing Your Information. We collect and use information about you pursuant to applicable law, contractual obligations, and with transparency and fairness. The legal basis for processing depends on the products or services you use and how you use them. We rely on the following lawful grounds:
- Consent. Where appropriate or legally required, we collect and use your information subject to your consent.
- Performance of contract. We collect and use information about you to enter into a contract with you or to perform a contract that you have with us.
- Legitimate interests. We collect and use information about you for our legitimate interests, for example to deliver the products and services that you request, to market the products and services that you request or that we think you may be interested in, and to optimize your experience with our Site and Services.
- Compliance with laws. We may also collect and use information about you: (i) as required by law, such as to comply with a subpoena or similar legal process, (ii) when we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud, or respond to a government request, or (iii) if we are involved in a merger, acquisition, or sale of all or a portion of its assets.
11. Contacting Us
If you have any questions about this Privacy Notice or our privacy practices, please feel free to contact us at V2@theVersion2.com.
12. Changes to this Privacy Notice
We reserve the right to change or add to this Privacy Notice from time to time and will post any revisions on this Site. We will indicate at the bottom of the Privacy Notice when it was most recently updated. We encourage you to check back often to review the latest version.