Privacy Policy

Effective Date: December 31, 2019

This Privacy Policy describes how Acknowledge Digital Marketing LLC (“AKDM,” “we,” “our,” or “us”) collects, uses, and shares information about you and applies to your use of any online service location that posts a link to this Privacy Policy, including our website located at http://acknowledgedigital.com, and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). By using the Service, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree with this Privacy Policy, then do not use the Service.

This Privacy Policy does not apply to information collection activities outside of the Service, such as AKDM’s products and services that AKDM’s clients may use to collect information on their own behalf (unless otherwise stated below or at the time of collection). For information about processing on behalf of our clients, please see the section entitled “Information on Behalf of Our Clients” below.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are in Europe or a California resident, please see our location-specific disclosures in the “Additional Disclosures for People in Europe” and “Additional Disclosures for California Residents” sections below.

Information Collection

Information You Provide to AKDM
AKDM collects information that you voluntarily submit to AKDM through the Service. The categories of information we collect and have collected in the last 12 months include:

  • Contact Data, including your or your employer’s name, email address, phone number, and physical address; and
  • Job Applicant Data, including your employment and education history, such as transcript, writing samples, and references as necessary to consider your job application for open positions.

Do not submit any information to us that we have not requested.

Information Collected Automatically
AKDM also automatically collects certain information about your device and how your device interacts with our Service. The categories of information we automatically collect and have collected in the last 12 months include your device’s IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Service, and your browsing habits on and usage of the Service through your device.

We use various current and later developed technologies to collect this information (“Tracking Technologies”), including the following:

  • Cookies. A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.
  • Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisements that contains a pixel, the pixel may permit us or another party to drop or read cookies on your device. Pixels are used in combination with cookies to track activity by a particular browser on a particular device.
  • Location-identifying Technologies. Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Analytics and Advertising” and “Your Rights and Choices” below.

Information on Behalf of Our Clients.
We provide marketing and advertising products and services for our clients, and may collect and process information about individuals at the direction of our clients (“Client Data”). Client Data has historically included contact data, demographic data, social handles, content, internet activity, and location data, among other information. Our processing of Client Data is governed by the terms of our service agreements with our client, and not this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

AKDM acknowledges that you may have rights in connection with Client Data. If your information has been processed by AKDM on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to AKDM, please provide the name of the AKDM client on whose behalf AKDM processed your information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

Information from Other Sources.
We may obtain information about you from other sources. The categories of other sources from which we collect and have collected information from in the last 12 months include:

  • Social networks when you reference our Service or grant permission to us to access your data on one or more of these services;
  • Partners with which we offer co-branded services or engage in joint marketing activities; and
  • Publicly-available sources such as data in the public domain.

Use of Information
AKDM uses information we collect for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:

  • To operate and manage our Service;
  • To perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service;
  • To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • To prevent and address fraud, breach of policies or terms, and threats or harm;
  • To monitor and analyze trends, usage, and activities; and
  • To improve the Service or other AKDM websites, applications, marketing efforts, products and services.
  • To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
  • To provide you with advertisements; and
  • To fulfill any other business or commercial purposes disclosed to you and with your consent.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

Sharing of Information
AKDM shares information we collect through the Service in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information within the last 12 months, are as follows:

  • Service Providers. Our agents, consultants, and other service providers (collectively “Service Providers”) may process your information in connection with their work on our behalf. These Service Providers are contractually prohibited from retaining, using, or disclosing your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other commercial purposes.
  • Affiliates. We may share your information with our affiliates for internal business purposes. For example, we may share your information with our affiliates for customer support, marketing, or technical operations.
  • Vendors and Other Parties. We may share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising, see the “Analytics and Interest-based Advertising” section below.
  • Sweepstakes, Contests, Promotions. We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by other parties. If you voluntarily choose to enter a Promotion, your information may be disclosed to other parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
  • Clients. We share information with our clients in connection with us processing information on their behalf. For example, we share information with our clients in order to address your requests, market and advertise to you, and otherwise comply with applicable law.
  • Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Service rules or policies, or the rights of other parties or to investigate any suspected conduct which AKDM deems improper. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any other party.
  • Consent. We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with other parties or affiliates except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

Social Media and Technology Integrations
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated, owned, and maintained by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. For example, we hyperlink from our Services to websites, social media platforms, and other services not operated or controlled by us. These other parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use one of their features, both we and the applicable other party may have access to and use information associated with your use of that feature. If you publicly reference our Service on a social network (e.g., by using a hashtag associated with AKDM in a tweet or post), we may use your reference on or in connection with our Service.

The information collected and stored by other parties, whether through our Service, or another parties’ service or device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. AKDM is not responsible for and makes no representations regarding the privacy practices of other parties. You should carefully read their own privacy policies before providing any information to such parties.

Analytics and Advertising
Our Service also contains Tracking Technologies, some which are operated by vendors or other parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other parties may use Tracking Technologies on our Service and other services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on other websites or devices after you have left the Service (“Interest-based Advertising”).

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

Your Rights and Choices

Tracking Technologies Choices
Most browsers are initially set up to accept cookies; however, you generally can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilize all features of the Service.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Analytics and Interest-Based Advertising
You may exercise choice regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Some of the parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit http://www.aboutads.info/choices. In addition, some of these parties may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Communications
You have the option to opt-out of receiving promotional emails from AKDM by clicking on the unsubscribe link that appears at the bottom of every promotional email that is sent out to you by AKDM in relation to this Service, or contacting us at [email protected] with the word UNSUBSCRIBE in the subject field of the email. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions.

Data Security
We take reasonable steps to help protect the security of your information. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put into place physical, electronic, and managerial procedures. However, due to the inherent open nature of the internet, we cannot guarantee the security of your information collected through the Service.

Children
The Service is not intended for users under the age of 13, and we do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with personal information, that child’s parent or guardian should email us at [email protected] or send us a letter to the mailing address in the section entitled “Contact Us” below. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

International Transfer
Our Service is maintained in the United States of America, and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. and other countries or jurisdictions around the world. Data protection laws in the U.S. and other countries may be different from those of your country of residence. By using the Service, you freely and specifically give us your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. or any other jurisdictions where we conduct business or provide services. If your data is collected in the European Union, we will transfer your personal data subject to appropriate or suitable safeguards, such as standard contractual clauses.

Changes to this Privacy Policy
We may amend our Privacy Policy at any time and will post those changes on this page, so you can understand what information we collect, how we use it, and under what circumstances we may disclose it. Any changes will be effective immediately upon posting of the revised Privacy Policy. However, if we plan to materially change the way in which we use or disclose your information, we will provide you with prior notice and a chance to opt-out of such differing uses.

Contact Us
If you have any questions about this Privacy Policy, the practices of this Service, or your dealings with this Service, you can contact us at [email protected].

In addition, our mailing address is:
Acknowledge Digital LLC
197 Grand Street, Suite 5S
New York, NY 10013
USA
Attention: Privacy Compliance

For European-specific requests, you can contact our Data Protection Officer at [email protected].

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at [email protected].

Additional Disclosures for California Residents

Applicability of Offline Information Collection.
If you are a California resident, this Privacy Policy also applies to information collected off of the Service. By using the Service or interacting with us offline you agree and consent to our information practices described in this Privacy Policy.

Roles.
Our Service is intended to provide information to our business clients and job applicants. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) AKDM conducting due diligence regarding, or providing or receiving a product or service to or from your employer. If you are a California resident, see the sections entitled “Information on Behalf of Our Clients” above for information on how to exercise your rights.

Shine the Light.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at [email protected] or send us a letter to the mailing address in the section entitled “Contact Us” above. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that AKDM is not required to respond to requests made by means other than through the provided e-mail address or mail address.

California Consumer Privacy Act – (CCPA)
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the “Information Collection” section above. We collect this information for the business and commercial purposes described in the “Use of Information” section above. We share this information with the categories of third parties described in the “Sharing Of Information” section above. AKDM does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Disclosures for People in Europe

Roles
European data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

In limited circumstances, AKDM (located at the address set forth in the section entitled “Contact Us” above) operates as a controller, such as in connection with data collected from users who browse our website. However, AKDM generally operates as a processor on behalf of our clients. The clients are the controllers and determine the purposes for which and the manner in which personal data are to be processed by AKDM. Please visit the applicable client’s privacy policy for information about their privacy practices. Any questions that you may have relating to the processing of personal data by AKDM on behalf of a client and your rights under data protection law should be directed to the client as the controller, not to AKDM.

Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

Your Data Subject Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please e-mail us at [email protected] or send us a letter to the mailing address in the section entitled “Contact Us” above and specify which right you intend to exercise. We will respond to your request within 30 days. For information on how to exercise your rights for information collected and processed at the direction of our clients, see the section entitled “Information on Behalf of Our Clients” above. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a supervisory authority.