Complementics Network End User Privacy Policy

Last updated: August 17th, 2021


California Residents: If you are a California Resident, please see the Addendum for California Residents’ Privacy Rights for more information pursuant to the California Consumer Privacy Act (“CCPA”), which provides you with additional information and choices as to how we process your Personal Information.


EEA/UK and Swiss individuals: if you are located in the EEA/UK or Switzerland, please see our GDPR Privacy Notice which provides you with additional information and choices as to how we process your Personal Information.


We will inform you if additional notices about our use of your personal information apply to specific websites, products, services, or jurisdictions. Where applicable, these notices supplement and/or clarify this Privacy Policy and provide you with additional information and choices as to how we process your personal information.


Your Privacy


This Privacy Policy (“Policy”) tells you how Complementics and its subsidiaries (“Complementics”, “we”, “us”, “our”) collect, use transfer, store, disclose and protect (collectively, “processing”) the personal information of our customers, vendors, and website users as well as people whose personal information is collected on the Complementics Network and in other locations online when they interact with our content or services (“you”, “your”).


The “Complementics Network” is organized by Complementics; the other participants in the Network are entities that are our customers. As further described below, as part of the Complementics Network, we may collect or receive your precise location, information about your usage of the app, and your device’s Advertising ID. This information is collected through our clients’ mobile apps and services that have incorporated our technology (tags and software development kit, known as “SDK”), so that we can provide mobile ad measurement, analytics and other ad services to our customers. these customers use our technology to collect information, including your Personal Information, on their websites and mobile apps and share it with us, so that we can share it with other customers.


In this Notice we refer to “Personal Information” as any information that identifies, could be used to identify or is otherwise linked or reasonably linkable with a particular individual or household, as well as any information defined as “personal data,” “personal information” or equivalent term under applicable privacy laws. This Policy also describes the rights you may have with respect to our processing of your Personal Information. If you are NOT an EEA/UK or Swiss individual: To the extent permitted by law, by disclosing your Personal Information to us or using our services, you understand and agree that Complementics may collect, use and disclose your Personal Information in accordance with this Privacy Policy.


Information We Collect


The actual Personal Information we collect and how we use it, depends on the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain Personal Information.


Information You Provide Directly To Us: We may collect personal information about you (such as your name, address, and contact details) directly from you. For example, when you fill out our ‘Contact Us’ form, subscribe to our mailing lists, register for one of the events we host or sponsor, register for an account with us, submit a request or inquiry to us, or otherwise provide us information through our websites, we may collect Personal Information such as your name, company name, job title/position, business affiliation, email address, phone number and other contact details, your contact preferences and interests, information related to your inquires or requests, and certain offline data, such as registries of calls, or information we use to accommodate you at one of our events, such as event-related preferences or restrictions. If you contact us for customer support or other support and customer related service requests, we maintain support tickets and relevant records related to the requests.


Information Collected Automatically: When you download or use any mobile app of one of our customers that is part of the Complementics Network, we will automatically collect information, including Personal Information, about your precise location, your usage of the app and your device’s Advertising ID, in order to share it with other customers of ours.


We may collect Personal Information about how you use our websites and related services (e.g. by using cookies and pixel tags), such as your Internet Protocol address, MD5 hashed address if applicable, location information (including with your consent precise geolocation information) , browser type, operating system, advertising ID, device ID, and information regarding what website pages you accessed and when and how, date and time of your visit to our website, and the information for which you searched and which you viewed. We also use cookies and other tracking technologies to make our web services more useful to you and to tailor the experience with us to meet your special interests and needs. We may also use pixels in HTML emails to understand if individuals read the emails, we send to them (“usage data”). We may combine this information with other information that we have collected about you, including, where applicable, your name and other Personal Information.


See also Cookies and other tracking information below.


Information we collect from third parties: In some cases, we may also collect Personal Information about you from third party sources, such as public databases, co-branded services, joint marketing partners, social media platforms or other third-party platforms.


Co-Branded Third-Party Services: You may sometimes see Complementics content on third-party sites, included co-branded websites and services. When you browse such third-party sites, you are subject to that company’s respective privacy practice and policy, not this Policy.


Aggregate and de-identified data: We may de-identify and aggregate certain data we collect such that the data no longer identifies or can be linked to a particular customer or an individual data subject, subject to the terms of any applicable agreement with you. We may use this de-identified data to improve our products and services, analyze trends, publish market research, and for other marketing, research or statistical purposes, and may disclose such data to third parties for these specific purposes.


How We Use Information We Collect


The purposes for which we may process Personal Information will vary depending upon the circumstances and your relationship with us. In general, we use Personal Information for the purposes set forth below:


  • Operate the Complementics’ Network and our services and websites, and provide related support, including to communicate with you about your use of our websites and services, provide troubleshooting and technical support, undertake bug-prevention in our services, respond to your inquiries, process your payments, communicate with you, and for similar service and support purposes
  • Provide you with information and services you request, including to respond to your inquiries, fulfill your orders and requests
  • Customize content, advertising, and your experience on the Complementics Network using our services and websites, including to tailor content we may send or display to you such as to offer location customization and personalized help and instructions, and to otherwise personalize your experiences
  • Communicate with you about service updates and other administrative issues
  • Measure and improve our sites and services
  • Analyze site and user behavior and prepare aggregated reports
  • Tell you about our services and those of our corporate family products and services on third-party websites, as well as for direct marketing and advertising purposes, including to send you newsletters, alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them
  • Protect our legal rights and preventing misuse, such as to protect our websites, business operations; enforce agreements and resolve disputes; prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy
  • Comply with our legal obligations, for example to comply with the law or legal proceedings, including to disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements, or respond to requests in connection with litigation or dispute resolution
  • Related to our general business operations, for example to implement mergers, acquisitions, reorganizations, and other business transactions (including any related negotiations), and where necessary to the administration of our general business, accounting, recordkeeping and legal functions


Aggregate, De-identified or Anonymous Data: We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to constitute Personal Information.


Sharing and Disclosure


Generally, we may share Personal Information as follows:


  • Affiliates. We may disclose your Personal information to our affiliated companies whose handling of personal information is subject to this Policy.
  • Service providers. We may disclose your Personal information to our service providers so they can perform services on our behalf, such as our payment processors, hosting providers, auditors, advisors, consultants, and customer service and support providers.
  • Third-Party Partners. We may partner with third-party advertisers to serve ads, including targeted ads, who collect certain information, including Personal Information, when you visit our websites. These third parties may use cookies or pixels to collect such data during your visit to our website in order to help show you more relevant advertisements on other websites and other forms of media. We also disclose Personal Information to third parties for purposes of personalization, modeling, customer onboarding, and data linkage including for measurement and analytics on campaign performance.
  • Business transfers. As our business evolves, we may sell, transfer or otherwise share some or all of its assets in connection with a financing, merger, reorganization or sale of assets, or in the event of bankruptcy. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
  • Legally required. We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, in response to a subpoena or court order including national security or law enforcement disclosure requirements).
  • Protect our rights. We may disclose information where we believe it necessary to respond to claims asserted against us, resolve disputes or comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of us, our clients, and others.


Cookies and other tracking Information


EEA/UK and Swiss individuals: if you are located in the EEA/UK or Switzerland, please see our Cookie Policy here.


We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the websites and other services. We may combine this “usage data” with other Personal Information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.


Managing your cookie preferences: You can manage your cookie preferences for our websites and opt out of certain cookies by editing your browser options as explained below.


Cookies: Cookies are alphanumeric identifiers that we transfer to your device or computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.


Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.


Third-Party analytics: We may use third-party analytics companies to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.


Do not track (DNT): Our Sites currently do not respond to “do not track” signals. You may, however, disable certain tracking mechanisms in the cookie preference settings of your web browser and opt out of certain third-party ad cookies on our websites.


Interest-based Ads


On Our Websites. We may work with third party ad networks, ad exchanges, channel partners, measurement services and others (“third party ad companies”) to personalize content and advertising on our website and services, and to manage our advertising on third party sites, mobile apps and online services. In order to display more relevant ads on our behalf and others, we and these third party ad companies may use cookies, pixels tags, and other tools (which we may refer to collectively as “targeting cookies”) to collect browsing and activity information on our websites and services, on third-party sites and across different devices, which may be linked with certain offline data. We and they may also collect IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information about you. We and these third party ad companies may use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. As a result, our ads may be displayed to you on a search results page or on third party sites.


Complementics Network. As part of the Complementics Network we provide mobile ad measurement, analytics and other ad services to our customers, and for that purpose we may collect or receive your precise location, information about your usage of the app, and your device’s Advertising ID, all collected through our clients’ mobile apps and services that have incorporated our technology (tags and software development kit, known as “SDK”). This information is used and will be disclosed by us to our customers in order for our customers and other third parties to serve you personalized content and ads, measure ad performance, and conduct related analytics and reporting. You may opt-out of our collection of this information through our online opt out form at complementics.com/opt-out or by adjusting your device privacy settings:



If you later start sharing your Advertiser ID (i.e., by changing the privacy settings for your device), your opt out will no longer be effective. Please note that if you opt-out of sharing your Advertiser ID, advertisers and publishers will not be able to use your Advertiser ID for any targeting or tracking through your device. But if you also want to opt out of further disclosures of your Advertising ID by Complementics, please submit your Advertising ID to us as explained at complementics.com/opt-out.


Your Ad Choices


Complementics adheres to the Digital Advertising Alliance (“DAA”) industry self-regulatory principles for online behavioral advertising. You may obtain more information about targeted or “interest-based advertising” and on how to opt out by visiting www.aboutads.info/choices.


As noted above, you may also control how we or third parties display certain ads to you, as explained further in the respective privacy policies and ad preferences pages. You may opt out of the collection of data collected by using tools provided by industry groups such as the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (the “DAA”). You can learn more about the information collection practices and "opt-out" procedures of many third-party ad companies by visiting www.networkadvertising.org/optout_nonppii.asp. You can also obtain more information about targeted advertising, and how to opt-out of targeted advertising by participating members, through the following:


U.S. Users: www.aboutads.info/choices (Digital Advertising Alliance)


Users in Canada: http://youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)


Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. Please note that these tools only prevent collection of data pertaining to you on the browser on which they are installed, and will only function if your browser is set to accept third-party cookies. If you delete an opt-out cookie from a browser’s cookie files, we will collect data from that browser until an opt-out cookie is reset on that browser; so, if you delete cookies, block cookies or use another device, your opt-out will no longer be effective.


Marketing Communications


We may send periodic direct marketing communications or promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. Please note that if you opt out of receiving emails about recommendations or other information, we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.


Access and Update Information


You may access, update, and delete certain of your Personal Information by contacting us using the information in the Contact Us section below to make a request regarding your Personal Information. You may also visit complementics.com/opt-out for more options to stop sharing personal information with us. Please note that we may maintain copies of information that you have updated, modified or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law.


Links to Third-Party Sites


Our websites and services may contain links to other third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the respective privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications.


Security


We have taken steps to help protect the Personal Information we collect, including through implementation of physical, electronic and administrative safeguards. However, no data security measures can guarantee 100% security.


Children's Privacy


Complementics's website and services are not targeted to children under thirteen (13) years of age and we do not knowingly collect Personal Information from children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such personal information from our systems. If you believe that we might have collected information from a child under 13, please contact us at [email protected]


Changes to This Policy


This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time at our sole discretion, so please be sure to check back periodically. If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as by changing the effective date of the Policy or notifying you at your email address of record. If you are NOT an EEA/UK or Swiss individual: Your continued use of the website and our services following a change in the Policy represents your consent to the updated Policy to the fullest extent permitted by law.


Contact Us


If you have any questions about this Policy or our privacy practices, you may contact us at [email protected]


Email: [email protected] | Telephone: 312-477-7313 | Address: 1074 W Taylor St, #371, Chicago, IL 60607

© 2021 Complementics