Privacy Policy

Updated September 2021

This privacy policy (the “Policy”) describes how ITN Holdings, LLC (“ITN” or “We”) collects, uses and shares personal information in connection with ITN’s website, user platforms and products and services (referred to herein as the “Services” and/or “ITN Property”). 

This Policy is incorporated in and subject to the Terms of Usage (the “Terms”).  ITN may modify this Policy from time to time which will be effective upon its posting.  It is important that you review the Policy often.  YOUR USE OF THE SERVICES CONSTITUTES YOUR CONFIRMATION OF AGREEMENT TO THE POLICY THEN IN EFFECT AT THE TIME OF YOUR USE.  If You do not agree to this Policy, do not use the Services. 

This site may contain links to other third party web sites. We are not responsible for the privacy practices or the content of such web sites.

 

AD Serving Policy

ITN collects IP addresses for geotargeting, user agent strings to identify the type of device to deliver the optimized creative for that device.

When you interact with our advertisements, ITN receives and stores information about your use of the advertisement, such as:

• internet protocol (IP) address

• browser type

• internet service provider (ISP)

• referring/exit pages

• operating system

• date/time stamp; and

• clickstream data

 

ITN collects this information passively using technologies such as beacons and tags.

ITN may receive reports based on the use of these technologies by third party companies on an individual and aggregated basis.

ITN may use such information (together with other information that we obtain in accordance with this Privacy Notice):

• to analyze and better understand the interaction with our advertisements;

• to analyze and better understand the interaction with our advertisements (for example by monitoring the total views of our advertisements);

• to provide additional functionality to our advertisements; and

• to gather demographic information about users who view our advertisements; and

• to either display advertising on our Digital Properties or to manage our advertising on other websites and apps.

 

ITN is a member of IAB, we use AAID/IDFA to deliver customized advertising.

 

Users can follow these steps to reset or turn off AAID/IDFA:

 

Reset Advertising ID on Android

 

  • The steps for resetting your ad ID and turning off ad personalization are essentially the same for all versions of Android, though things may vary slightly. Head to Settings > Google > Ads > Reset advertising ID and click OK when the confirmation screen appears. It would be best if you also wanted to make sure to opt-out of ads personalization. Or, on other versions of Android, it might say "Opt-out of interest-based ads," and you may find a toggle switch or checkbox to enable it.

 

Reset Advertising Identifier on iOS

  • On your iPhone or iPad, head to Settings > Privacy > Reset Advertising Identifier and then Reset Identifier when the prompt comes up. Just like with Android, here, you should also turn on the option to limit ad tracking.

 

How do I reset or limit Ad Tracking on mobile devices?

  • Your mobile device may be enabled to serve you targeted ads. If you are using an Apple device such as an iPhone, iPad, iPod touch and Apple TV you can turn off location-based ads provided by Apple. Instructions on how do this can be found here: https://support.apple.com/en-us/HT202074.

  • If you are using a device that uses Android software such as a mobile phone and tablet, you can turn off certain types of ads. Instructions on how to do this can be found here: https://support.google.com/ads/answer/2662922?hl=en.

 

Tracking technologies and web beacons:

  • ITN may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has seen our advertisement. This allows us, for example, [to monitor the traffic patterns of users from one advertisement  to another and to count the number of views].

 

Collection and Use of Non-Personal Information

We may collect non-personal information regarding your use of the Services through methods that are not apparent during use of the Services. Such information is collected through software tracking technologies described below.

Examples of non-personal information collected using tracking technologies include information about user activity, such as pages viewed, geographic location of visitors and/or devices used by visitors, among other examples. 

In some cases, information regarding visitor activity may be considered personal information under applicable law, such the IP address associated with a visit to the Services which can in some situations act as a unique identifier for a user device.  Where information collected in such manner constitutes personal information, it is subject to the provisions of this Policy governing all personal information.

If you do not want information collected in these ways, it may be possible for you to adjust settings on the devices you use to access the Services (e.g., a computer, smartphone or tablet).  However, we cannot guarantee that such settings may be changed or will be effective and you assume all risks associated with your access to the Services.

Collection and Use of Personal Information

 

We may also collect Personal Information about you, either directly collected from your submissions during use of the Services or indirectly through tracking technologies as described herein.

By “Personal Information”, we mean information that can be used to identify a specific individual.  Personal Information may include, for example, name, email address, physical address, phone numbers, device identifiers, IP addresses, and/or software tools such as “cookies” (“Cookie Data”).    

Your Personal Information may be used to operate the Services generally and/or to provide the Services you have requested or authorized specifically.  Access to some Services may necessitate use of Personal Information.  We may collect your personal information when you participate in, access or sign up for any of our Services or contact us via electronic mediums.  Certain Services you have requested access to require that we provide Personal Information to third parties, which will only be done with your knowledge and consent.

Your Personal Information may also be used to improve the Services and/or make them easier to use or customized to your particular preference or interests.  We may additionally use your Personal Information to provide you with information about our services, such as new features or updates to the Services, marketing, and/or to comply with applicable laws and law enforcement. 

We may also use your Personal Information to provide you with information about other Services you may be interested in.

Note that certain aspects of engaging with ITN are subject to additional or different terms and policies, such as submissions relating to potential employment and data provided in connection with professional engagement.  In these circumstances, we’ll explain further why we’re collecting your information and how we’ll use it prior to any collection of your information. 

 

Tracking Technologies and Targeted Interaction

We may utilize our own or third party software to collect information about you and other visitors to the Services.  We reserve the right to change our data collection methods, providers and/or software, at any time in our sole discretion. 

We use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Service, track users' movements around the Services, and to gather statistical and demographic information about our user base as a whole, among other uses discussed in this Policy.  We may receive reports about user activity on an individual and aggregated basis.  In addition to the other uses of Personal Information described herein, we may use Cookie Data to remember users' settings (e.g., language preference), and for authentication.

If you do not want information collected using tracking technologies, it may be possible for you to adjust settings on the devices you use to access the Services (e.g., a computer, smartphone or tablet).  Users can typically control the use of cookies at the individual browser level. If you reject cookies, you may still use our Services, but your ability to use some features may be limited.  We also cannot guarantee that settings may be changed or will be effective and you assume all risks associated with your access to the Services.

 

How We Process Personal Information

Personal data we collect may be transferred or be accessible internationally.  Use of our Services is intended for individuals in the United States only, but you understand that by using the Services, you consent to any storage, processing and transfer of information into and out of your country, state, and/or territory. 

Generally accepted technical standards are used to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Cyberattacks of U.S. companies by criminals has increased over recent years and created a significant risk in any company’s day-to-day operations.  As a result of these circumstances, we cannot guarantee the absolute security of any data, including our own, and thus cannot be liable for security breaches.

By using the Services and providing any information to us, you are acknowledging that not all portions of the Services are secure and that data transmissions via email, uploaded through a network or on the Services are inherently insecure. You acknowledge and agree that use of the Services is at your own risk.  

We will not intentionally disclose your Personal Information other than as we have disclosed, but we cannot control and will not be liable for interference by third-parties. 

Given the inherent risks, You agree not to provide any information through the Services, including any communication with us, that you would not want shared with others, or information that would cause you damage or irreparable harm.

 

WE WILL NOT HAVE ANY LIABILITY WHATSOEVER FOR ANY DATA BREACH OR UNAUTHORIZED ACCESS TO USER INFORMATION COLLECTED OR SUBMITTED THROUGH THE SITE AND SERVICES.

 

Disclosure of Personal Information

ITN may disclose your Personal Information as necessary to ITN’s business, provision of the Services, such as to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Examples of ITN disclosures in this regard including disclosing to vendors that assist ITN with Services operations and/or delivery of Services. 

We may also disclose your information for other reasons permitted under the law, including if we determine a violation of the Terms has occurred, or if we believe such disclosure is necessary to identify or bring legal action regarding or prevent injury or interference with our rights or the rights of another user of the Services, or to respond to legal process or as otherwise required by law, or to assist us in fraud protection or investigation, or to protect the integrity of the Services or safety of other users.

In any instance where we are disclosing your information to a third party, we shall take appropriate precautions to ensure your information is handled in accordance with the law.

 

Retention and Deletion of Personal Information

We generally retain your information for as long as necessary to enable the uses described herein or as otherwise allowed by law.

You may request a copy or deletion of the information we hold about you via request through the contact information below and such information shall be provided, subject to confirming your credentials and authority, and unless doing so is otherwise prohibited or exempted by law.  You may also contact us to have any inaccuracies in your information corrected, or limit further use of your information, subject to the same exceptions.

Users have the opportunity at any time to remove themselves from our communications.  Users also can request their Personal Information be deleted by responding to the opt-out information provided on our Services, or in our emails, or by contacting us using the contact information provided below. 

Notwithstanding the foregoing, you acknowledge and agree that withdrawal of consent and deletion of your data is subject to exceptions where ITN determines, in its sole discretion, that retention of the data is necessary, including but not limited to the following examples:

 

1. Withdrawal of consent shall not apply where retention of your Personal Information is necessary for ITN to fulfill certain uses disclosed here such as legal requirements, investigations and/or where data has been disclosed to third parties in accordance with the Terms and this Policy.

2. After disclosure of Personal Information to third parties pursuant to the Terms and this Policy, withdrawal of consent and deletion of your Personal Information may not be possible and/or may be subject to the limitations of such third parties’ own privacy policies or other requirements similar in scope to those disclosed here.

 

3. Withdrawal of consent and/or deletion of your Personal Information may not be possible where otherwise required by legal authorities.

 

Children’s Privacy

We do not knowingly collect or solicit personal information from minors and you represent and warrant that you are not providing any information about a minor.

 

Contact For Any Privacy Concerns:

ITN Holdings, LLC
Attn: Privacy Director
Email: privacy@itnnetworks.com

 

Additional Policy Provisions for California Residents

This section (“CCPA Section”) supplements the information contained in the Policy and applies solely to users of the Services who are residents of the State of California.  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this CCPA Section.

Personal Information for purposes of the CCPA Section is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“CCPA Personal Information”). 

CCPA Personal information does not include (a) Publicly available information from government records; (b) Deidentified or aggregated consumer information; or (c) information which is not within the scope of CCPA.

Categories of CCPA Personal Information we have collected within the last twelve (12) months:

Category
Examples
Collected
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers
Yes
B. Personal information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
No
C. Protected classification characteristics under federal or California law
Age, race, color, ancestry, national origin, citizenship, religion, marital status, medical or health conditions, disabilities, gender, sexual orientation, military status, or genetic information
No
D. Commercial information
Records of purchasing
No
E. Biometric information
Fingerprints or facial recognition
No
F. Internet activity
Browsing or search history
No
G. Geolocation data
Physical location or movement
Yes
H. Sensory data
Audio or visual information.
No
I. Employment related information
Employment status or history
No
J. Non-public education information under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Education records directly related to a student maintained by an educational institution
No
K. Inferences from other personal information
Profile reflecting a person's preferences
No

We obtain such CCPA Personal Information from you directly or from third parties you have authorized or are necessary to provide the Services you have requested, and/or indirectly through Tracking Technologies.  We may use or disclose CCPA Personal Information for the reasons described in the Policy.  We will not collect or use CCPA Personal Information other than as disclosed pursuant to the Policy including this Section without notice to you.

Where we have disclosed CCPA Personal Information to a third party for the purposes described in the Policy and this Section, we require such third parties to treat such CCPA Personal Information confidentially and only for the purposes we have disclosed to you. 

Your Rights as a California Resident

CCPA provides California Residents with specific rights regarding their CCPA Personal Information, specifically California Residents:

 

1. Have the right to request disclosure by use of our collection and use of your CCPA Personal Information in the preceding 12 months:

 

  • Which categories of your CCPA Personal Information we collected

  • Why we collected your CCPA Personal Information

  • What categories of third parties we shared your CCPA Personal Information with

  • The specific CCPA Personal Information of yours that we collected

 

2. Have the right to request deletion of your CCPA Personal Information that we possess

 

We will respond to verified requests from California Residents pursuant to the CCPA and fulfill such requests in compliance with the law, including any exceptions that may apply such as when the CCPA Personal Information is necessary to

  • fulfill our obligations with respect to the Services you have requested or another legal obligation

  • protect against cybersecurity threats, fraudulent or illegal activity

  • avoid damage to, maintain and repair our Services

  • the exercise of free speech or other rights protected under the law

  • comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)

  • the completion of scientific, historical, or statistical research you previously consented to which is in the public interest and in compliance with law

  • our right to use such information for internal purposes consistent with consumer expectations given the nature of our relationship with you or compatible with the context in which you provided your CCPA Information

 

You may exercise your CCPA rights described above and as otherwise provided under the law by submitting a verifiable CCPA request to the contact specified in the Policy for any privacy concerns.  Such a request must be:

 

1.  made by you or your registered agent authorized pursuant to California law, on your behalf or on behalf of your minor child

 

2. Made no more than twice in any 12-month period

 

3. Provide information sufficient to reasonably verify the CCPA Personal Information is yours or is your minor child’s CCPA Personal Information

 

4. Provide sufficient detail to allow us to evaluate the request and our legal obligations and rights under the law

We will respond to verifiable CCPA requests in accordance with the requirements of the law, and reserve all of our rights under such law.

We will not discriminate against you for exercising your CCPA rights as a California Resident, and will not deny access to Products or Services in the manner provided to all users of such Products or Services except as permitted by the CCPA.

This Section may be amended in our discretion except to the extent otherwise required by law.

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