Privacy Policy

Conversion Logic, Inc. (“Conversion Logic”, “we”, “our”, and “us”) offers a technology platform that helps marketers understand the value of various offline and online channels. For digital ads we do this by tracking media exposure (the users who saw an ad), media response (i.e., the users who clicked an ad) and conversion (i.e., the action a Client hopes a user will take – an online purchase, a registration, or similar). Conversion Logic is committed to protecting your privacy. This Privacy Policy (“Policy”) explains our privacy practices regarding the information that we collect, use, share, and secure from visitor to https://conversionlogic.com/, (our “Website“), our technology platform (the “Platform“), our services (“Services“) and any information collected from those who use our Platform and Services (our “Clients“).

We collect information in various ways when you use our Website, and Services and when Clients leverage the Platform via their respective websites. Our products and services are used by businesses and our Website is directed to businesses; not consumers. We do not sell consumer data as part of our Platform or Services.

INFORMATION COLLECTED VIA OUR WEBSITE AND FROM CLIENTS

Information Collected Automatically When You Use Our Website and Services: Through the use of cookie technology, Web beacons or other technologies (as described below), we may track and collect information about your computer and software when you visit our Website. This information can include your IP address, domain server, type of computer, type of web browser, access times; and referring websites addresses. This information does not personally identify you. Among other things, this information assists us to design and arrange our web pages in the user-friendliest manner and to continually improve our Website to better meet the needs of our Clients and prospective Clients.

Information You Volunteer: In order for you to access certain services and information that we offer via the Website or otherwise, we may require you to provide us with information that personally identifies you, such as your name, mailing address, email address and home and business telephone numbers. If you communicate with us by email, or otherwise complete online forms, surveys, or the like, any information provided in such communication may be collected.

Information We Collect When You Contact Us: When you contact our support team or communicate with us in any other way, we’ll collect whatever information, files, materials, or data that you volunteer at that time.

Information We Collect From Clients and Prospective Clients: When you become a Client, we will collect an email address and ask you to select a password so that you may login to our Platform. We may also ask you for your phone number, title, company address and similar information. We will also collect billing information. We will also collect information for current and prospective Clients to help us market our services to them and will provide options to opt-out of such communications within those communications as required by law. Before we use your information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out of such use. For more information you may contact us at privacy@conversionlogic.com.

 

Cookies and other Tracking Technologies: Conversion Logic employs cookies on its Website in order for its server to recognize a return visitor as a unique user. We also enable third parties to place cookies to help us conduct analytics on the Website, to manage leads, or to help us advertise our Services via Google or social media platforms such as Facebook and LinkedIn. In places like the State of California, the use of these third party cookies may be considered a sale of data and you may find out more about your privacy choices for by clicking on the link for each company. Cookies are small text files placed in the ‘Cookies’ folder on a visitor’s hard disk and allow Conversion Logic to remember the visitor. The cookies placed by Conversion Logic’s server are readable only to Conversion Logic, and cookies cannot access, read or modify any other data on a computer. All web-browsers offer the option to refuse any cookie. If a visitor refuses the Conversion Logic cookie, Conversion Logic does not gather any information on that visitor, but doing so may require you to re-enter certain information at each visit, or prevent us from customizing the Website’s features according to your preferences. You may also delete a cookie manually from your hard drive. For more information about cookies, please visit http://www.allaboutcookies.org/cookies/.

 

How We Use Information Collected via the Website and from Clients

Conversion Logic may use your information to register you to use Conversion Logic’s services and/or products, contact you to deliver certain services, materials or information you may have requested (e.g., a request for information by clicking on our (i) “Contact Us” tab, or (ii) “Request a Demo” tab on the Website), verify your authority to enter into certain areas of the Website, improve the content and general administration of the Website and our services, provide you with notices regarding our services, and, with your permission, administer Client accounts as described above and provide you with updates and information about Conversion Logic and its services. Generally, you will be given the opportunity to “opt-in” to receive Conversion Logic newsletters, white papers or specific marketing material.

We may also use information collected to monitor and analyze trends and track usage and user movement on the Website, develop, improve, and refine products, services, and functionality and gather broad demographic information for aggregate use (see below for more details). As with other sites and services, we may also use this information to prevent fraud or other unauthorized or illegal activity as well as to promote safety and security. In short, we reserve the right to use this information in order to carry out any other purpose for which the information was collected.

INFORMATION COLLECTED VIA OUR TECHNOLOGY PLATFORM

Overview of Data Collection via the Platform

Conversion Logic’s Services include data collection, user mapping, and user path analysis – the results of which are delivered solely to our Clients in aggregated form. Data collection is a process that centralizes, cleans and normalizes data from each of the Client’s marketing vendors and each source where a consumer engages in a desired behavior (for example: a purchase which occurs on a Client’s website). Our Clients, who are generally businesses seeking to market a product or service, use this information in order to help them optimize marketing programs.

In order to provide the Services, Conversion Logic works with Marketers, Marketing Vendors and Third Party Data Providers.

Marketers: Conversion Logic offers its services to digital marketers that advertise to consumers and may work with them directly or indirectly through an Advertising Agency they employ.

Marketing Vendors: The companies that provide marketing services to Marketers. This may include digital marketing such as Search Engine Marketing, Email Marketing, Display Advertising or others. It may also include vendors that provide offline marketing such as for television, radio or mail.

Third Party Data Providers: Conversion Logic works with companies that assist in stitching user data together from disparate sources. For example, companies that provide offline purchase data for Marketers.

 

What data does Conversion Logic collect via the Platform?

Our Platform receives data each time a Client’s ad is viewed or clicked, including the following:

  • – A Unique ID – Our systems collect a pseudonymous unique identifier relevant to the source of data. For browsers this will be from a unique user id created by Conversion Logic and placed into a cookie. On mobile devices, we use the mobile advertiser ID provided by the mobile O/S (i.e., the – Apple ID for Advertising (IDFA) or the Android Advertising ID (AAID). On a Connected TVs, we use the subscriber ID provided by the connected TV manufacturer. None of these IDs may be used by Conversion Logic to identify an actual person, but they allow our Platform to unique identify a browser, computer, TV or mobile device over time.
  • – Ad serving and log file data – Our systems also obtain information about the ad that was served including ad campaign meta-data provided by the Client, the date/time the ad was served, the user agent and IP address (which helps us infer city, region or country), the referrer and the landing page URL of an ad clicked on. This information is only stored temporarily for testing purposes.
  • – Client provided data – In addition to the above information our Clients may provide us additional identifiable information about you including a unique user identifier created by each Client, the total amount spent on a purchase, whether or not you are a returning customer or other relevant dimensional data (e.g. a segment you belong to or relevant to an event completed on their site).

How does Conversion Logic use the data collected via the Platform?

Conversion Logic primarily uses the data collected about your browser or device to provide our Services, which include:

  • – User-path management – Our platform collects data about your browser or device over time to create what we call a “user path”. A user path helps our Clients better understand whether their ads are engaging and driving users to visit their sites and/or purchase their products and services, among other things.
  • – User segmentation – Our Platform will collect “meta-data” over time which enables our Clients to place their users into profile segments such as “new customer” and “existing customer” which helps them better understand the effectiveness of their marketing programs.

What Tracking Technologies does Conversion Logic use on the Platform?

Conversion Logic collects data in various ways. Some Clients allow us to place tracking pixels, JavaScript tags and place cookies onto their websites. In these cases, we use cookies to uniquely identify users over time as ads are viewed, clicked on and other actions performed on a Client’s website. Other Clients simply pass data to us directly, or via their market vendor or third-party partner such as their ad server.

We also engage in cookie synching and other forms of ID synchronization. ID Synchronization occurs when Conversion Logic provides known user identifiers to a 3rd party data provider who then identifies the user within their dataset and map their unique identifier to the identifier provided by Conversion Logic. Conversion Logic engages in ID synchronization with 3rd party data providers in order to identify users that Conversion Logic thinks as separate users which that provider may know is the same user and to augment user path data; that is to add knowledge of non-digital media stimulation, media response and conversions to user paths.

On a mobile device we will use cookies within a browser app or we will collect data through server-to-server (postback) integrations with individual application owners and the mobile analytics companies that they have integrated with.

HOW WE SHARE INFORMATION WE COLLECT

We do not generally share your information with third parties without your consent other than:

  • – Third Party Service Providers – With third party agents and service providers including: a) cloud computer, data storage and file storage providers, b) email marketing providers and ad servers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors. These agents work on our behalf and use data only as directed by us, provided that such third party agents provide at least the same level of privacy protection as we do;
  • – Marketing Analytics and Optimization – Conversion Logic shares aggregated data collected via the Platform with Clients and their marketing partners in order to inform Client media plans and strategy.
  • – Lawful Requests – To comply with laws or to respond to lawful requests and legal process (provided that Conversion Logic will endeavor to notify you if Conversion Logic has received a lawful request for your information). Note that we may be required to provide information about you in response to lawful requests from public authorities including to meet national security or law enforcement requirements.
  • – Protection of Rights and Property – To protect the rights and property of Conversion Logic, our agents, customers and others including to enforce our agreements, policies and our terms of service.
  • – Emergency – In an emergency, including to protect the personal safety of any person; and
  • – Corporate Restructuring – For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). In the event of an insolvency, bankruptcy, or receivership, information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the  information collected by us and will assume the rights and obligations regarding your  information as described in this Policy.

We may transfer information to companies that help us provide our Services. Conversion Logic is responsible for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Privacy Shield principles if its agent processes such Personal Data in a manner inconsistent with the Privacy Shield principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

OUR SECURITY MEASURES

Conversion Logic maintains commercially reasonable administrative, technical, and physical safeguards to help protect the information we process in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. We utilize encryption/security software to safeguard the confidentiality of information we collect from unauthorized access or disclosure and accidental loss, alteration or destruction. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us or from our online services, and you do so at your own risk.

CHILDREN

We do not intentionally gather information that is personally identifiable from visitors who are under the age of 16. If you are under the age of 16, you are not permitted to submit any information to us. If we learn that a child under 16 submits information to Conversion Logic we will attempt to delete the information as soon as possible. If you believe that we might have any information from a child under 16, please contact us at privacy@conversionlogic.com.

THIRD PARTY WEBSITES, AD CHOICES AND CHOICES ABOUT THE PLATFORM

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other websites accessible through our Website have their own privacy policies and data collection, use and disclosure practices. Please consult each website’s privacy policy. We are not responsible for the policies or practices of third parties. We may allow third-party advertisers to serve ads and/or collect data from our Website. Some of those companies will use information about your visits to this Website and other websites in order to tailor advertising messages to you on this and other websites. This practice is sometimes called online behavioral advertising. For more information about this practice and to better understand the choices available to you, please visit http://www.aboutads.info/. A number of industry groups are attempting to develop a Do Not Track (DNT) standard. Currently, the standards regarding the DNT signals and appropriate responses are not defined. Accordingly, we do not assign a meaning to DNT signals.

If you don’t want the Conversion Logic Platform to track you then you can opt-out by blocking our domain. Conversion Logic stores cookies on the following domains: “c.conversionlogic.net” and “www.conversionlogic.com” although we try not to place cookies collected via our Platform on browsers operated by EU data subjects. If you’d like your browser to restrict the cookies being set by our Platform, please click on the instructions below.

ACCESS RIGHTS, DATA RETENTION

If you would like to access, change, suppress or otherwise limit our use and disclosure of your Personal Information that has been previously provided to us, you may contact us by sending an email containing your request to privacy@conversionlogic.com.

Conversion Logic acknowledges that California EU and Swiss individuals have the right to access and delete the Personal Data that we maintain about them. A California individual seeking to understand their access, deletion or opt-out rights, or an EU or Swiss individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their Personal Data, should contact us at privacy@conversionlogic.com. We will also provide an individual located within the EU or Switzerland with choice before we share their Personal Data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. In each event, you must clearly indicate the information that you wish to have changed or suppressed or clearly indicate the limitations you wish to put on our use of your Personal Data. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. More information about privacy rights for EU, Swiss and California data subjects may be found below.

Please note: If you are a consumer and want to see what data we may have on behalf of one of our customers, kindly reach out to that individual customer. Conversion Logic is contractually prohibited from honoring such requests without specific written instructions from the applicable customer.

Retention Period. Except for the information collected via the Platform and Services, which is governed by the privacy policies of our Clients, we will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. You may request that we change or delete your Personal Data by following the instructions above.

CALIFORNIA DATA SUBJECTS

Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.

 

If you are a customer or partner and have questions about your ability to see the data used to login to our systems, we ask that you direct your question to the person that owns the business relationship. If you are a consumer and want to see what data we may have on behalf of one of our customers, kindly reach out to that individual customer. Conversion Logic is contractually prohibited from honoring such requests without specific written instructions from the applicable customer.

 

You may access those rights with respect to Conversion Logic by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email to privacy@conversionlogic.com. As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days.

 

The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.

 

We may take reasonable steps to verify your request.  We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.

You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.

INDIVIDUALS IN THE EEA

Individuals located in the European Economic Area (“EEA”) are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, an EU (or Swiss) individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their Personal Information, should send us an email at privacy@conversionlogic.com.

With respect to EU data subjects, Personal Data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.

Conversion Logic operates the Platform and provides the Services as a “data processor” under the GDPR. That means Conversion Logic only processes data via the Platform and Services as directed by our Clients and for no other purpose. We process certain Personal Data provided by Clients and partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services. We collect contact details from EU data subjects via our Website with consent and ask for consent for our Website to place cookies onto EU desktops. Although we try not to place cookies collected via our Platform on browsers operated by EU data subjects, you may visit our Cookie Policy page to see information about the cookies placed via the Website. Our sales and marketing team may obtain additional contact details for current and prospective Clients via our legitimate interest so long as they are not overridden by your data protection interests or fundamental rights and freedoms.

Conversion Logic’s data protection officer and EU representative is Dr. Christoph Bauer, CEO at ePrivacy GmbH and he may be contacted at privacy@conversionlogic.com.

PRIVACY SHIELD

Conversion Logic complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries and Switzerland. Conversion Logic has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page once it is available, please visit https://www.privacyshield.gov. Conversion Logic is subject to the investigatory and enforcement powers of the FTC.

CHANGES TO THIS POLICY

Conversion Logic may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. You agree that your continued use of our Website, Platform or Services after such changes have been published to our Policy will constitute your acceptance of such revised Policy.

CONTACT CONVERSION LOGIC WITH QUESTIONS OR COMPLAINTS

If you have any questions about this Privacy Policy, the practices of our Website, Platform, or Services, or your dealings with our Website, Platform or Services, please contact us at privacy@conversionlogic.com, or send mail to:

Conversion Logic
12300 Wilshire Blvd, Ste 200
Los Angeles, CA 90025
Attn: Privacy Team

Privacy Complaints by persons located in the European Union and Switzerland. In compliance with EU-US and Swiss-US Privacy Shield, Conversion Logic commits to resolve complaints about your privacy and our collection or use of your Personal Data. Persons located in the European Union and Switzerland who have inquiries or complaints regarding this privacy policy should first contact Conversion Logic at privacy@conversionlogic.com or via the address provided above.

Conversion Logic has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.