Data We Receive
Comlinkdata uses data in order to support its Business Services. Business data may be considered personal data in some jurisdictions, including the European Union. Our Business Services are not directed to children under 16 years of age, and we do not knowingly collect information about children.
Comlinkdata may receive the following data from Partners: Device Information, such as device type and model, network provider and connection type, cookie identifiers, mobile carrier, mobile IDs, MAC address, IMEI, unique identifiers, hardware type, device specifications, operating system, IP address, location, Internet service provider, and other actions taken through the use of the Business Services, Information about the Property, such as Property ID, app name, website, mobile website URL, app ID, and bundle ID, and Information Provided By Other Partners, such as demographics, age, interests, preferences, gender, zip or postal code, advertiser ID, and Device Information.
What Do We Do with Business Data?
Comlinkdata uses business data in aggregate to perform research about market performance, and model future market performance for the benefit of our Clients.
Process Data on Behalf of Our Clients. Our Clients may choose to use our Business Services to process certain data of their own, which may contain personal information. If the data that we process through our Business Services is solely processed by us on behalf of our Clients, their privacy policies and/or the contracts we have in place with them will govern how they use the data. If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Business Service to process this data. Our Clients control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our Clients to address any concerns you may have, in accordance with the terms of our contract with them.
Research and Development. We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our Business Services or develop new products. We may perform research via surveys and engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Business Services, various types of communications, advertising campaigns, and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We will use de-identified individual and aggregated data for research and analysis purposes.
De-identified and Aggregated Information Use. We use business data, personal information and other information about individuals to create de-identified and aggregated information, such as demographic information, location information, information about the computer or device from which individuals access our Business Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions. This information is not personal information, and we may use such information in several ways, including research, internal analysis, analytics, and any other legally permissible purposes. We share this information within Comlinkdata and our Clients for our or their purposes in a de-identified or aggregated form.
Other Uses. Comlinkdata will use information to enforce Comlinkdata’s terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Business Services, and to take any action in any legal dispute and proceeding.
Sharing Information with Others
We may share information for the following purposes with:
- Customers: We share aggregated information and research about market trends with our Clients.
- With our employees: On a need-to-know basis Comlinkdata allows employees to access data so that we might service our customers or develop new products.
- Vendors and Service Providers: For example, for website and data hosting, or hiring auditors to review and ensure our privacy policies and practices meet the highest standards. All service providers have appropriately executed contracts that prohibit them from using or sharing personal information except as necessary to perform their services.
- Law Enforcement and Others: If we are legally required to do so or if we need to protect our rights or the rights of third parties.
Cookies, Social Media, Analytics & Advertising
Consent. You have the right to object to and change your preferences or opt out of certain uses and disclosures of your personal information. Where you have consented to our processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us at email@example.com. Even if you opt out, we, our Clients and third parties may still collect and use information regarding your activities on the Services, Properties, websites and applications and/or information from advertisements for other legal purposes as described herein.
In accordance with the California Consumer Privacy Act, if you are a California resident you may contact us with your request to opt out of Comlinkdata data processing by emailing us at firstname.lastname@example.org, or use this form. Please include “CCPA Privacy” in the subject line of your email.
Your California Privacy Rights
The California Consumer Privacy Act provides residents of California with certain legal rights in respect of their personal information.
The Right to Know: the right to request that a business that collects, sells, and/or discloses for a business purpose personal information about the consumer disclose to the consumer the following: the categories of personal information it has collected, sold, and/or disclosed for a business purpose about that consumer; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting or selling personal information; the specific pieces of personal information the business has collected about that consumer; the categories of third parties to whom the personal information was sold.
The Right to Delete: the right to request that a business delete any personal information about the consumer which the business has collected from the consumer.
The Right to Opt-out: the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
The Right to Non-Discrimination: a business shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
Your particular jurisdiction may utilize a different definition of Personal Information than the CCPA.
The above legal rights are subject to various conditions and exceptions. We take steps to help ensure that you able to exercise your rights. However, the pseudo-anonymous nature of our data may mean that it is impractical to satisfy certain requests as it is materially difficult or not possible to associate data with your identity. To make a request in accordance with the California Consumer Privacy Act, please send an email to email@example.com with “CCPA Privacy” in the subject line, or use this form.
Your Rights in Business Data
If we have received business data that contains personal information from our Clients, we will refer your requests to them directly. In accordance with applicable law, you may have the right to:
• request confirmation of whether we are processing any of your personal data;
• obtain access to or a copy of your personal data;
• receive an electronic copy of personal information that you have provided to us or ask us to send that information to another company (the “right of data portability”);
• restrict our uses of your personal data or object to those uses;
• seek correction of inaccurate, untrue or incomplete personal data;
• request erasure of personal data about you;
• withdraw your consent where you have consented to processing; and
• lodge a complaint with your supervisory authority, subject to certain exceptions prescribed by law.
If you would like information about how to exercise any of these rights or if you have concerns about the way Comlinkdata processes your personal information, you are welcome to contact Comlinkdata at: firstname.lastname@example.org. Comlinkdata will look into your inquiry and make good-faith efforts to resolve any existing or potential dispute with you.
Comlinkdata stores and retains business data for as long as instructed by its Clients and for its personal data as long as necessary to fulfill the purposes for which it was collected, provide our Business Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. Our Clients and other third parties may have different practices, and you should refer to their privacy policies.
Transfer of Data Outside Your Territory
Comlinkdata may store and process information in various locations throughout the United States in sites operated and maintained by cloud-based service providers and other service providers.
Comlinkdata is committed to safeguarding the confidentiality of personal information it collects and its Clients’ business data. Comlinkdata and its hosting services make reasonable efforts to secure personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, Comlinkdata cannot guarantee that the Business Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Notes on this Privacy Charter
This document does not encompass or detail Comlinkdata’s handling of internal employee or customer data. Comlinkdata’s employees and customers may provide additional personal information such as names, email addresses, and phone numbers through the regular course of business and Comlinkdata’s non-public facing policies, which are available to those groups, govern the handling of that data.
Last Updated: January 3, 2020