This Policy was last updated on July 31st, 2018.
A “controller” is the legal entity which, alone or jointly with others, determines the purposes and means of the processing of personal data. Interact is the data controller for all data described by this policy with the following exception: Data collected when individuals participate in a quiz, poll, or promotion offered in connection with our Service (“End-User Data”) is controlled by the Interact User that created the poll, quiz, or promotion.
A “processor” is a legal entity or other body which processes End-User Data as described above on behalf of the controller, as defined above. Interact is a data processor for Data collected at the direction of Interact Users using the Interact Service.
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available in connection with our Service. Users may be asked for, as appropriate, first name, last name, company name, phone number, zip code, payment information, Google Analytics ID, and Facebook Pixel ID. Users may also, visit our Site anonymously.
When you interact with our Service, we also collect limited non-personally identifying information that the browser you used makes available automatically. This information includes the internet address of the computer or network you used to access our site, the date, time, and page(s) you visited on our Site, the browser and operating system you used, and the referring page (the webpage that contained the link to our site that you clicked on to get there). Once you leave our Site, you have the right not to be followed. When you access our home page, you will see at the bottom of the page an option to update your cookie preferences. We encourage you to manage your experience by clicking on the preference option.
We have a legitimate interest in ensuring that our Site operates correctly and efficiently. To that end, we use the aggregated nonpersonal data and information from all users of our Site to measure server performance, analyze user traffic patterns, and improve the content of our Site and portions of our Service. We sometimes track the keywords that are entered into our search engines or through our Services to measure interest in specific topics and to improve the User and visitor experience on the Site and in connection with our Service.
We have a legitimate interest in communicating with you about your account, and will use your personal information to send you important non-commercial emails, such as administrative notices related to our Service and customer service inquiries. For instance, you will receive notices, as described later in this policy, regarding downloading the End-User Data you have collected through our Services.
Please note that unless you delete your account completely, as outlined below, we will continue to send you such noncommercial messages, even if you have opted out of receiving commercial messages from Interact. If we detect that your account has been dormant for a period of 18 months, we will send you an e-mail reminder containing instructions to keep your account open. If the instructions are not completed and by the requested time as outlined in the e-mail, we will close your account and delete your information and your account permanently, retaining only that which we are required by law to keep.
We have a legitimate interest in complying with our legal obligations. Accordingly, we may release personal information if we believe in good faith that: the law or legal process requires it; we have received a valid administrative request from a law enforcement agency; or such release is necessary to protect our rights, property, or safety, or that of our respective affiliates, business partners, customers, or others.
In the event Interact conducts an online promotion, contest, or sweepstakes (collectively, a “Promotion”), information we collect will be used consistent with the terms and conditions outlined in the promotion guidelines or rules, which may include a reference to this Policy. You can elect to provide permission for Interact to use the email address and/or telephone number you provide when entering a Promotion for sending you marketing messages. However, you are only required to provide such permission in order to participate in a Promotion if it is necessary for the running of the promotion. For instance, if we request your email address or your social media handle because it is used to notify you if you’ve won and/or to send your prize, and you do not want to provide it, you will not be able to participate in the Promotion. Information you provide us will be used to administer the promotion. If you have not opted in to receive further communications about upcoming promotions, your identifying data will be retained only for as long as it is necessary to administer the Promotion and legally comply with our obligations.
If you would like to revoke your consent to receiving commercial messages you have previously opted in to receive as the result of a Promotion, you can use the unsubscribe link in any marketing message, or reply “STOP” to any marketing text message you receive. You may also send an e-mail to email@example.com that contains the email address or phone number you wish to revoke consent for marketing messages.
Interact will provide End-User Data to the User that collected it. Interact keeps End-User Data for a period of 18 months, time sufficient for the User to review, understand, and download this End-User Data, after which time, Interact will destroy the End-User Data. If Interact does not detect that the End-User Data has been downloaded by the User, Interact will remind the User to download the data at least one time prior to destruction of the data.
When you sign up for one of our plans, we will collect your payment information. We use Stripe to collect and process your payment information. The safety of your credit card information is important to us, and Interact makes commercially reasonable efforts to help protect the security of information you provide online in connection with a purchase.
Pursuant to your reasonable request, we will provide you or a third-party you specify with a list of all of your personal information that Interact has collected, in a form that is portable to you.
Similarly, upon your request, we will make corrections to our records of your personal data.
With regard to End-User Data, we provide Users with a "Portability" function, which allows Users to download all information collected about an individual.
As described above, some of the online services available through our Service allow you to register for an account or provide personal information. You will be asked for applicable information to create an account, including name, email address, and a preferred password for your account. All personal information we collect is stored and processed in the United States and/or Europe.
We keep your information only for as long as we have a legitimate business purposes, and only that information required for the particular purpose for which you became a User. We will retain your personal information while you have an active relationship with Interact, including if you have subscribed to a newsletter, or opted in to receive commercial content from us, have visited the site while logged in, have ordered a product, participated in a promotion, or have affirmatively made requests of us that we, or our data processors, are fulfilling. We will maintain your information for eighteen months after that relationship ends, unless you request that we delete your information prior to the expiration of that period, which you may do at any time following the instructions here. Except as required under the law, your request will be honored within 30 days. If Interact determines that it no longer requires your information for the purposes set forth above, it will delete your information.
Unless instructed otherwise by the User that collected the information, Interact will delete End-User Data no later than 12 months from the date it is provided to Interact. Users can delete End-User Data for specific individuals at any time using our Service.
If you would like us to delete all of your personal information and/or remove your name and address from promotional lists (including any personal information gathered by our service providers) and place your name on our “do not contact” list, contact us at firstname.lastname@example.org and request that you be placed on our “do not contact” list. Please note that because names may be similar, you must include in your request all associated email addresses and phone numbers (if any) that you wish to be removed in the body of the email. We reserve the right to contact you for administrative purposes to request more information in order to assist us in deleting your account or information about you. For instance, if you send us an email using an email address that is not in our system, we may contact you to ask you for the email you used when you created your account. We may also send you a confirmation email, once we have deleted your information. We will make commercially reasonable efforts to delete your information within 30 days from our active files, provided, however, that we may retain—for legal compliance purposes only—your request and associated email in a hashed format so that we do not inadvertently restore your information to our database. Please note that requests to update your personal information may take up to five days. You may also request that we stop processing your information without deleting it, and we will comply within five days of receipt of such a request.
Notwithstanding the above, Interact will retain your information indefinitely if it believes in good faith that it has a legal obligation to do so.
To help us serve you better, we collect information that identifies the computer or browser used to access our Service, as well as the user account associated with that computer/browser if you are logged in. Cookies are pieces of information placed in the settings of your web browser by a website server to identify your computer when you return to a website. Whenever a site welcomes you and tailors data to your specifications, it is reading a cookie left in your browser and identifying information that you may have registered during previous visits, such as your viewing preferences.
Because the do-not track signal does not often reflect the preference of our consumers, our website does not respond to it. Users may, however, elect not to receive marketing messages and/or have certain cookies placed on their browser, as discussed earlier in this Policy.
Consistent with the Children's Online Privacy Protection Act of 1998 and its revisions in 2013, our website is a general audience website, intended for adult use only. Interact does not market to, and does not knowingly collect any personally identifiable information from children. If you are based in the EEA you may only use our Service if you are over the age at which you can provide consent to data processing under the laws of your country (the “Age of Consent”).
We take reasonable and appropriate security measures to protect unauthorized access, alteration or destruction of data located on and collected by our Service. Sensitive and private data exchange between the Service and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. We exercise reasonable care to protect your non-public personal information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your non-public personal information, we cannot guarantee the security of any information you transmit to us or receive from us while it is in transit. Once we receive your personal information, we maintain physical, electronic and procedural safeguards to protect it. If a data breach occurs, we will notify you and the proper EEA authority (if required) within 72 hours (if reasonably feasible). If we are unable to notify the proper EEA authority within 72 hours, our notice will be accompanied by reasons for the delay.
Interact holds all data we handle to the same standard which incorporates the General Data Protection Regulation (GDPR), a legal framework that sets guidelines for the collection and processing of personal information of individuals within the EU. EU individuals who have a complaint regarding the handling of their data pursuant to the GDPR have the right to file a complaint with the appropriate Data Protection Authority. If you are an EU individual who wishes to exercise this right please go to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate the appropriate DPA.
In order to consummate the business relationship, Interact may transfer EU and Swiss personal data to the United States. To that end we have self-certified with the Privacy Shield Frameworks which add an additional level of compliance and oversight for that transferred data. If you are an EU or Swiss individual whose data was transferred into the United States, the following notification applies to you.
Interact is subject to the regulatory and enforcement authority of the US Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks we are obliged to inform EU and Swiss individuals that we may be required to release their information in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
Interact is liable for the transfer of EU and Swiss personal data to third parties unless we can prove we were not a party to the actions giving rise to the damages.
Interact acknowledges the right of EU and Swiss individuals to access their personal data. Individuals wishing to exercise this right can login to their Interact account by visiting https://dashboard.tryinteract.com/login and navigate to Download Personal Data located under Account Settings section of the user dashboard.
Please note that Interact does not sell, rent or use personal data for reasons other than that for which it was originally provided by the individual. If any of those practices should change in the future, we will update this policy appropriately and provide individuals with opt-out or opt-in choice as circumstances require.
In compliance with the Privacy Shield Principles, Impact commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Interact at:
Interact has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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 https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
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