Effective as of May 14, 2018
We understand that when you use our Service, you trust us with your information. We understand this is a big responsibility and we work hard to protect your information and put you in control. Our commitment to transparent privacy practices means that we want to do everything we can to help you understand in plain English how we are collecting and managing your personal information.
We’ve tried to make this easy, but we understand that there are many terms that may be unfamiliar. Please feel free to email us at [email protected] for any questions or concerns. Your privacy and your ability to understand your rights and how we are collecting and managing your personal information are important to us.
Any users from the European Union should be sure to read the information provided below under “Additional Information for European Union Users”. You can find more information about European data protection laws here.
What does Lytics do?
Lytics is a software company that provides customer data; analytics and marketing intelligence software to help customers of our Service (“Clients”) better understand their consumers so they can deliver relevant marketing communications and campaigns.
Our Service aims to help our Client’s marketing communications and campaigns be more useful and relevant to consumers by showing them content and messages that are best tied to their specific interests and needs.
Personal Information We Collect
In the course of operating the Service and providing our services, we may collect the following types of information (collectively, the “Information”).
Information you give us
Personal information you may provide through the Service or otherwise communicate with us:
- Identity information, such as your first name, last name, user name or similar identifier, title, date of birth and gender;
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username an password, interests, preferences, feedback and survey responses;
- Feedback and correspondence, such as information you provide in survey responses, when you participate in market research, report a problem, receive customer support or otherwise correspond with us;
- Transaction information, such as your credit card or other payment and billing details;
- Usage information, such as information about how you use the Service and interact with us; and
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.
Information we collect
Apps, browsers and devices
Our servers may automatically record certain information about how you use our Site (we refer to this information as “Activity Data“), including both Clients and casual visitors.
Activity Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
Sensitive personal information
Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.
Information we get from others
We may obtain additional information about you from third party sources to enrich your experience on the www.lytics.com website and provide you with more relevant information related to our service offerings.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at [email protected]
How We Use Your Personal Information
To provide the Service
If you have a Lytics account, we use your personal information:
- To operate, maintain, administer and improve the Service;
- To manage and communicate with you regarding your Service account, if you have one, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
- To process payments you make through the Service;
- To better understand your needs and interests, and personalize your experience with the Service; and
- To respond to your Service-related requests, questions and feedback.
To communicate with you
If you request information from us, register for the Service or participate in our surveys, promotions or events, we may send you Lytics-related marketing communications if permitted by law, but will provide you with the ability to opt out.
To comply with law
We use your personal information, as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information or you opt into third party marketing communications.
To create anonymous data for analytics
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Compliance with Laws and Law Enforcement; Protection and Safety. Lytics may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Access, Update, Correct or Delete Your Information All Lytics account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Lytics account holders may also contact us at [email protected] to accomplish the foregoing or if you have additional requests or questions.
Access to Data Controlled by our Clients
Lytics has no direct relationship with the individuals whose personal information is contained within the Client User Data processed by our Service. An individual who seeks access, or who seeks to correct, amend, or delete personal information provided by our Clients should direct their request the Client. You may also contact us at [email protected] if you have additional questions or concerns.
You may opt out of marketing-related emails by logging in and changing your account settings or by clicking on a link at the bottom of each such email. You may continue to receive Service-related and other non-marketing emails.
If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us.
Tracking and Targeted Advertising
Choosing not to share your personal information
Where we need to collect your personal information by law, or to be able to provide the Service to you and you do not provide that information when requested (or you later ask to delete it), we may not be able to provide you with the Service and may need to close your account. We will tell you what information you must provide to receive the Service by designating it as required in the Service or through other appropriate means.
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Lytics is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. European Union users should read the important information provided further below under Cross Border Transfer Section about transfer of personal information outside of the European Economic Area.
Other Sites and Services
The Service may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Social Media Widgets
User Generated Content
We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use; storage or dissemination of such publicly disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.
Lytics does not knowingly acquire or receive personal information from children under 13. If we later learn that any user of our Service is under the age of 13, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
Additional Information for European Union Users
Controller and Data Protection Officer
Lytics, Inc. is the controller of your personal information for purposes of European data protection legislation. Our Data Protection Officer can be reached at [email protected] See the “Questions” section above for additional contact details.
Legal bases for processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at [email protected]
|Processing Purpose||Legal Basis|
|To provide the Service||Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service|
|To maintain and improve the Service||Processing is necessary to ensure that our Service is working as intended and to make improvements to the Service|
|Provide personalized services, including content and ads||Processing is necessary to customize our services for you, including providing recommendations and personalized content|
|Develop new services||Processing is necessary to help us develop new services|
|To communicate with you To measure performance with anonymous data for analytics For compliance, fraud prevention and safety||These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected]|
Use for new purposes
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction Information) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
- Contracts approved by the European Commission, which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
- For transfers to third parties in the United States, ensuring they participate in the E.U.-U.S. Privacy Shield Framework Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
Privacy Shield Frameworks
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Lytics or to which Lytics discloses personal information for use on Lytics’ behalf.
“Lytics” means Lytics, Inc. its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Lytics to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Lytics will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework.
Lytics is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Should a EU or Swiss individual be unable to resolve a complaint through the Council of Better Business Bureau's complaint process, they may contact the FTC at the following address:
Federal Trade Commission Attn: Consumer Response Center 600 Pennsylvania Avenue NW Washington, DC 20580 www.ftc.gov