PRIVACY POLICY of ViralGains, Inc.
Last Updated: May 2024
- ABOUT VIRALGAINS
ViralGains provides ad journeys that enable advertisers to place marketing videos and display content on third-party publisher websites and other online channels, and allows consumers to view, interact with and share advertisements.
The services we provide include:
- Surveying and analyzing consumer preferences;
- Developing and enhancing audiences and marketing segments; and
- Placing and serving advertisements and surveys on third-party websites and services.
In this Privacy Policy, we refer to these activities as “Services.”
- WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy explains how we handle the personal information of our business customers and prospects, as well as the personal information of consumers whose information we process through our Services.
- PERSONAL INFORMATION WE COLLECT
We collect the following categories of personal information:
Business information (including contacts, communications and analytics):
We may collect personal information about our business customers and prospects, including names, email addresses, phone numbers, mailing/billing addresses, employer names, job titles, as well as information contained in our business communications. We use cookies and other automated technologies to collect information regarding how visitors interact with our website and how business recipients interact with our marketing communications. We may also receive information about business prospects and customers through Meta, Instagram, LinkedIn, X, and other social media.
Consumer information:
- Survey information: We may collect information that consumers provide in response to our surveys. Consumers may choose to provide information that may reveal their brand preferences, location, and demographics, including attributes such as race, ethnicity, health, sexual preferences, and any other information that consumers chose to share.
- Geolocation information: We may automatically collect geolocation information from the consumer’s device via their browser or mobile device location services.
- Internet activity information: We may collect or receive information about how consumers visit, use, and interact with the Services, including the advertisements and surveys that consumers view or click on, navigation and browsing patterns, purchases and advertising conversions, web traffic information, IP addresses, browser type and settings, and other log information.
- Device information: We collect information about the devices that consumers use to view or access our Services, including the name of the device, operating system, and browser. Information collected may depend on the type of device and its settings.
Information from other sources:
In certain cases, we combine consumers’ personal information that we collect through the Services with the personal information we obtain from our business customers and advertising partners. We work with third-party data providers that allow us to enrich and augment the information we collect by combining it with information these providers may collect from public sources and online activities. The information we obtain from these third parties may include information about advertisements that consumers view, advertising preferences and interests, demographic information, and purchases.
- HOW WE USE PERSONAL INFORMATION
We may use personal information for the following purposes:
To provide the Services and operate our business:
- To provide, maintain and improve the Services;
- To deliver targeted advertisements via our ad journeys;
- To develop and enhance marketing segments and analysis for our business customers;
- To report on the performance of a specific advertising campaign to an advertiser;
- To respond to inquiries, comments, feedback, or questions;
- To analyze how consumers interact with our 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;
- To comply with applicable laws, legal obligations, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; and
- To protect our rights, privacy, safety, or property, and/or that of our affiliates or other third parties.
To develop marketing segments: We use consumer personal information to understand consumer trends and preferences, and to develop marketing segments that our business customers can use to better tailor and target their advertising.
To market and advertise to our business customers and prospects: We may use personal information about our business customers and prospects to market and advertise our Services, including for direct marketing and online interest-based advertising.
- HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to the following categories of third parties:
- Business customers: We may disclose or otherwise make available consumer personal information to our business customers. We may augment data provided by our customers or create new audiences that we share with customers.
- Service providers: We may share personal information with companies and individuals that provide services on our behalf or help us operate our Services and our business (such as hosting, information technology, customer support, email delivery, website analytics services, payment processors, and customer relationship management). These parties will access, process, or store personal information in the course of performing their duties to us.
- Advertising vendors: We may share personal information with third-party advertising companies, including for interest-based advertising purposes and to support our business customers’ advertising activities.
- Business transferees: 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”), we may share personal information with counterparties and others assisting with the Transaction and to a successor or affiliate as part of or following the Transaction.
- Legal requirements:We may 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 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.
- PRIVACY RIGHTS AND CHOICES
We offer privacy rights and choices to individuals whose personal information we process. Please note that in some circumstances we may direct consumers to submit their privacy-related requests to our business customers. This happens when we process consumer personal information on behalf of our business customers in our capacity as a “service provider” or “processor.”
Here are the rights and choices we offer:
Opt out of marketing emails: To opt out, send an e-mail to privacy@viralgains.com or click on the “Unsubscribe” link located on the bottom of any ViralGains marketing email.
Personal information requests: We provide the following rights and choices, depending on the individual’s location and the nature of their relationship with ViralGains:
- Information about how we have collected and used personal information. We have made this information available without having to request it by including it in this Privacy Policy.
- Access to a copy of the personal information that we have collected. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
- Opt out
- Limit the use of sensitive personal information, where the personal information we collect about consumers is considered “sensitive” under applicable U.S. state privacy laws.
To make a request, please click the “Do Not Sell My Personal Information” link in the footer of our website or email or write to us as provided in the “Contact Us” section below. We may ask for specific information to help us confirm identity. We do not discriminate against individuals for exercising their rights.
In some instances, these rights and choices may be limited, such as where fulfilling a request would impair the rights of others, our ability to provide a service, or our ability to comply with our legal obligations and enforce our legal rights. Individuals who are not satisfied with how we address their request may submit a complaint by contacting us as provided in the “Contact Us” section below.
Third-party tools for limiting online tracking: There are various tools that consumers may use to limit online tracking. These tools are not controlled by ViralGains and we cannot guarantee that they work as advertised.
- 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 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:
- Google Advertising ID (AAID) page (for Android users to Limit Ad Tracking and Opt Out of Interest-Based Ads).
- Apple Identifier for Advertisers (IDFA) page (for iOS users to Limit Ad Tracking and Opt Out of Interest-Based Ads). See also Apple’s Advertising & Privacy page.
- Download the DAA’s AppChoices application 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.
Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- DATA RETENTION
Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information, and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
- CHILDREN
Our Services are 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 Services please contact us and we will endeavor to delete that information from our databases.
- JOB APPLICANTS
We collect information about job applicants through the Careers portion of our website. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that applicants voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating an applicant for an employment opportunity, to monitor recruitment statistics and to respond to surveys. We may also use this information (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation, and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms of use.
- LINKS TO OTHER WEBSITES
The Services 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.
- SECURITY
We implement commercially reasonable technical, administrative, and organizational measures designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free.
- CHANGES TO THE PRIVACY POLICY
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 applicable law.
- CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@viralgains.com or:
Attn: Privacy Agent
ViralGains Inc.
75 State Street, Suite 100
Boston, MA 02109
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Last Updated: November 2023
Here is a snapshot of the categories of personal information we may have collected about you over the past 12 months, how we may collect your personal information, how we may use your personal information, to whom we may disclose your personal information, and whether you can limit the sharing.
For a complete list of the categories of personal information we collect, how we use that information, and the categories of third parties to which we disclose personal information, please see the main Privacy Policy section above.
Category | Do We Collect? | How We Collect | Primary Purposes of Processing | Key Recipients / Disclosures | Can You Limit Sharing? |
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name | Yes | When you visit or use our Services; when you apply for a job with us | To provide our Services; to improve, monitor, and personalize our Services; to communicate with you; for marketing and advertising; to process your job application | Service providers | No |
Advertising partners and business customers | Yes | ||||
Characteristics of protected classifications under CA or federal law | Yes | When you apply for a job with us; When you visit or use our Services | To process your job application | Service providers | No |
Commercial information, including but not limited to records of personal property, products or services purchased, obtained or considered | Yes | When you visit or use our Services | To provide our Services; to improve, monitor, and personalize our Services; to communicate with you; for marketing and advertising | Service providers | No |
Advertising partners and business customers | Yes | ||||
Personal Information categories listed in the CA Customer Records Statute (e.g., name, contact details) | Yes | When you visit or use our Services; from third-party sites and services; when you apply for a job with us | To provide our Services; to improve, monitor, and personalize our Services; to communicate with you; for marketing and advertising; to process your job application | Service providers | No |
Advertising partners and business customers | Yes | ||||
Biometric information | No | N/A | N/A | N/A | N/A |
Internet or other electronic network activity information, including information regarding a consumer’s interaction with a website | Yes | When you visit or use our Services | To provide our Services; to improve, monitor, and personalize our Services; for marketing and advertising | Service providers | No |
Advertising partners and business customers | Yes | ||||
Geolocation data | Yes | When you visit or use our Services | To provide our Services; to improve, monitor, and personalize our Services; for marketing and advertising | Service providers | No |
Advertising partners and business customers | Yes | ||||
Audio, electronic, visual, thermal, olfactory or similar information | No | N/A | N/A | N/A | N/A |
Professional or employment-related information | Yes | When you visit or use our Services; when you apply for a job with us | To provide our Services; to improve, monitor, and personalize our Services; to process your job application; for marketing and advertising | Service providers | No |
Education information, defined as information that is not publicly available personally identifiable information as defined in FERPA | No | N/A | N/A | N/A | N/A |
Inferences drawn from information identified to create a profile about a consumer | Yes | When you visit or use our Services | To provide our Services; to improve, monitor, and personalize our Services; for marketing and advertising | Service providers | No |
Advertising partners and business customers | Yes | ||||
Sensitive Personal Information (as defined in CA Civil Code 1798.140 (ae)) | Yes | When you visit or use our Services; when you apply for a job with us | To provide our Services; to improve, monitor, and personalize our Services; for marketing and advertising; to process your job application | Service providers | No |
Advertising partners and business customers | Yes |