Privacy Policy

PRIVACY POLICY of ViralGains, Inc.

Last Updated: March 2021

ViralGains, Inc. (“ViralGains,” “we,” “us,” or “our”) owns and operates the website at (the “Site”). ViralGains provides ad journeys that allow advertisers to place marketing videos and display content on third-party publisher websites and other online channels and allows Consumers (as defined below) of advertisements to view, and sometimes to interact with and share, advertisements (collectively, including the Site, the “Service” or “Services”).


This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms and Conditions.

Your privacy is important to us. Before using the Service or submitting any Personal Information to ViralGains, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.


We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

Information Provided by our Customers: When you explore our website to learn about the Services ViralGains offers to businesses, or to enroll in our Services, you are considered a business customer (our “Customers”). We may collect the following categories of Information from our Customers or potential Customers when you provide it to us by entering your information into the ViralGains Site or registering to use the Service. While this information is usually provided on behalf of a business Customer, under certain circumstances, it might be deemed Personal Information.

  • Identification and Demographic Information: When Customers fill out our “Get in Touch” form, we may collect our Customers name, email address, phone number, mailing/billing addresses, company, job title category, current location, zip code, and
  • Financial Information: Our payment processor(s) will collect the financial information necessary to process our Customers’ payments, such as their bank account information.
  • Communication Information: We may collect information when our Customers contact us with questions or concerns and when our Customers voluntarily respond to questionnaires, surveys seeking our Customers’ opinion and feedback.  Providing communication information is optional to our Customers.
  • Information Provided by Individuals We Serve Ads To (“Consumers”): We may collect the following categories of Personal Information and internet activity information from Consumers when we are providing our ad journey through our Odyssey platform or other Services on behalf of our Customers. In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is necessary to use some features of our Site or the Services, you may be unable to use those features. You can also contact us to request updates or corrections to your Personal Information.
  • Internet Activity Information: When Consumers visit, use, and interact with our ad journeys, we may receive certain information about Consumers’ visit, use, or interactions.
  • Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies.
  • Geolocation Information: We may automatically collect geolocation information from your device via your browser or mobile device location services. Please consult your browser or device documentation regarding how to turn off location services. If you disable location services, you may not be able to use the full array of features and functionalities available through our Services.
  • We do not otherwise collect or process the Personal Information of Consumers.

Information Provided by Both Our Customers and Consumers:

  • Internet Activity Information: When you visit, use, and interact with the Services, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that interact with our Services, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g.,,, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information (e.g., city), and navigation pattern. In particular, the following information is created and automatically logged in our systems:
  • Log Information: Information that your browser automatically sends whenever you visit the Site or interact with our Services. Log Information includes your Internet Protocol (IP) address, browser type and settings, the date and time of your request, operating system, the external source by which you arrived at our Site or Services, the pages or ads you’ve clicked on, and how you interacted with the Site or Services. We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.
  • Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you interact with our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
  • Email Open/Click Information: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Aggregate Information or Information About Consumers’ Ad-Viewing Habits We Collect: We may receive aggregate information and information about consumers’ ad-viewing habits from third parties as part of your use of the Services and from third parties who may facilitate your use of the Services.

Derived Information: We may infer Consumers’ preferences for products and services based on the information we collect about Consumers.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time.

  • Session Cookies: We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser.
  • Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Site.

For more details on cookies please visit All About Cookies.

We also allow other companies that are presenting advertisements on some of our pages to set and access their cookies on your computer. Please note that ad networks’ use of cookies or web beacons, and that of any other third-party that has a link available on any Site, is subject to their own privacy policies and not this privacy policy.

If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of, and you may not be able to benefit from the full functionality of, the Site or the Services.

If you access the Site or interact with our Services on your mobile device, you may not be able to control tracking technologies through the settings.

Analytics: We use one or more third–party analytics services, such as Google Analytics (“Google”), to evaluate your use of the Site, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Site you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data. Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here.

By accessing and using the Site and interacting with our Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any third-party analytics service, you may not be able to use the full functionality of the Site or Services.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, and other advertising networks may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.

  • Behavioral and Interest-Based Advertising. You have additional controls and choices with respect to the collection and use of your information in certain circumstances. Many companies in the advertising ecosystem – including ViralGains—voluntarily participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or those who are members of the Network Advertising Initiative (“NAI”). To make choices about the use of information from or about you for online behavioral or interest-based advertising on websites (desktop and mobile browsers), please visit the DAA and the NAI.

To make choices about online behavioral or interest-based advertising within mobile applications (including exercising the choice to “Opt Out”), visit:

Additionally, you may:

  • download the DAA’s AppChoices application from your mobile device by clicking here or directly from your device’s app store;
  • visit this page (information provided by the NAI)*

*Note that the NAI link also provides general instructions on how to reset your Advertising ID.


We may use Personal Information for the following purposes:

  • To provide the Services;
  • To deliver targeted advertisements via our ad journeys;
  • To facilitate the delivery of advertising;
  • To report on the performance of a specific advertising campaign to an advertiser;
  • To respond to your inquiries, comments, feedback, or questions;
  • To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
  • To analyze how you interact with our Services;
  • To maintain and improve the Services;
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use Customers’ Personal Information to contact our Customers to tell them about products or services we believe may be of interest to our Customers. For instance, if our Customers elect to provide their email, we may use that information to send our Customers special offers. Customers may opt out of receiving emails by following the instructions contained in each promotional email we send. Customers can also control the marketing emails they receive by updating their settings through their account. In addition, if at any time our Customers do not wish to receive future marketing communications, they may contact us. If Customers unsubscribe from our marketing lists, they will no longer receive marketing communications but we will continue to contact our Customers regarding management of their account, other administrative matters, and to respond to their requests.


By providing any Personal Information to us, you fully understand and unambiguously consent to the transfer of such Personal Information and the collection and processing of such Personal Information to third parties described in this policy and our Terms and Conditions. We will not sell or rent your Personal Information to anyone other than as described in this Privacy Policy. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws. In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
  • Legal Requirements: We are required to disclose Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas. We may disclose Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with our rights or property, other end users, or anyone else that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce our contracts or user agreement, including investigation of potential violations hereof; and (iii) detect, prevent, or otherwise address fraud, security or technical issues. We may disclose Personal Information if we believe it is necessary to investigate potential violations of our Terms and Conditions for Advertisers, or to enforce those Terms and Conditions for Advertisers. The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
  • Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with ViralGains. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.


To “opt-out” of: (1) any consents previously given to us; or (2) receiving email communications from us, send an e-mail to If you have signed up to receive email newsletters, updates, or offers, you may opt out at any time from the use of your Personal Information for direct marketing purposes by emailing the instructions to or by clicking on the “Unsubscribe” link located on the bottom of any ViralGains marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. Notwithstanding this right to request to cease receiving communications from us, we retain the right to collect, maintain and process information provided by and collected about you on and through the Site, and disclose such information to comply with its reasonable business and legal obligations.


We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.


Where provided for by law and subject to any applicable exceptions, California residents may have the right:

  • To know the categories of Personal Information that ViralGains has collected about you, the business purpose for collecting your Personal Information, and the categories of sources from which the Personal Information was collected;
  • To access the specific pieces of Personal Information that ViralGains has collected about you;
  • To know whether ViralGains has disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;
  • To have ViralGains, under certain circumstances, delete your Personal Information;
  • To opt out: we may share Identification Information and Internet Activity Information with social media platforms and other advertising partners that will use that information to serve you targeted advertisements on social media platforms and other third party websites – under certain regulations such sharing may be considered a “sale” of Personal Information; and
  • To be free from discrimination related to the exercise of these rights.

If you would like to exercise any or all of these rights, you may do so by filling out the form here or contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Please contact us with questions or to request access to an alternative format of this Privacy Policy.

Third Party Marketing: If you are a California resident and wish to opt out of sharing your Personal Information with third parties for their direct marketing purposes, please email ViralGains at and clearly state your request, including your name, mailing address, email address, and phone number. Please see the “Your Choices” section of this Privacy Policy for additional information.

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties. These requests may be made once per year. To make such a request, please email us at or write us at:

Attn: Privacy Agent

ViralGains Inc.

75 State Street, Suite 100

Boston, MA 02109


Our Service is not directed to children who are under the age of 13. ViralGains does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to ViralGains through the Service please contact us and we will endeavor to delete that information from our databases.


The Service may contain links to other websites not operated or controlled by ViralGains, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.


You interact with and use the Services at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to ViralGains via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.


This Site and the Services are controlled and operated by ViralGains in the United States. The Site and Services are not intended for use outside the United States. By using or interacting with our Services, you understand and acknowledge that you use the Services at your own risk and that your Personal Information will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction.


The Site, or Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Site, interacting with the Services, or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.


If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: or:

Attn: Privacy Agent

ViralGains Inc.

75 State Street, Suite 100

Boston, MA 02109


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