The Comlinkdata Business Services Privacy Policy

Business Services
This Comlinkdata Business Services privacy policy (“Privacy Policy”) explains our privacy practices for processing business data for our customers (“Clients”). That data is provided from 3rd party data providers (“Partners”). Comlinkdata Business Services are to provide insights and analysis about market trends using aggregated versions of the data received from our Partners. Comlinkdata never provides its Clients with individual level information or any personally identifiable information (PII).

Comlinkdata has no direct interaction with the individuals from whom our Partners acquire data. Comlinkdata’s Partners are required to provide notice to individuals and to obtain the appropriate authorizations, consents and other lawful bases for the data they collect. Comlinkdata’s Partners are to provide a privacy policy of their own. Comlinkdata honors the IAB Europe’s Transparency and Consent Framework. For information about Comlinkdata’s Site and Website Services, please visit the Comlinkdata Website Privacy Policy.

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 on such users.

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 de-identified demographic information, de-identified 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. De-identified or aggregated information is not personal information, and we may use such information in a number of 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.

Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (sub-processors) to whom we entrust personal information include service providers for: IT and data augmentation services. We have executed appropriate contracts with our service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Law Enforcement and Others. We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; respond to your requests; protect your, our or others’ rights, property, or safety; to enforce our policies or contracts; to collect amounts owed to us; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs and other records may be reviewed for security purposes to detect unauthorized activity, illegal activity or fraud. In such cases, personal information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Cookies, Social Media, Analytics & Advertising
For the use of cookies and other Technologies on our Site and Website Services, please see our Website Services Privacy Policy.

Choice

Comlinkdata Business Services Account. If you have a Comlinkdata account for Business Services, your personal information is processed according to the Website Services Privacy Policy, and you may disable or delete your account by contacting us at contactus@Comlinkdata.com.

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 as described below. 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.

Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating third parties to which Comlinkdata has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. To make such a request, please contact us at: contactus@Comlinkdata.com

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: contactus@Comlinkdata.com. Comlinkdata will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you.

Data Retention
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.

To the extent necessary under EU privacy laws and regulations and/or its Client contracts, Comlinkdata will implement data onward transfer instruments.

Information Security
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.

Changes to this Privacy Policy
This Privacy Policy may change from time to time. If there are any material changes to this Privacy Policy, Comlinkdata will notify account holders through the Business Services, by email or as otherwise required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Business Services after the updated Privacy Policy is posted to this website. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Business Services.

Contact Us
If you have any questions, comments, or concerns, please contact Comlinkdata at:contactus@Comlinkdata.com.
Last Updated: December 3, 2018