AcornAds Privacy Policy




Last modified: July 15, 2016






Note: If you are a resident of Canada, please also see Canadian-specific privacy policy terms further below.




We at AcornAds, Inc. and the subsidiaries we own or control (collectively, "AcornAds") respect your privacy. We are
 publishing this version of the AcornAds Privacy Policy (the "Policy") to clearly disclose our practices and approach
 to data privacy and data protection.




This Policy describes how we collect, use, transfer, and safeguard information about you and your options regarding
 accessing or modifying such information. You accept and agree to this Policy when you visit a website on which this
 Policy is posted, create a AcornAds account, or interact with AcornAds' online and off-line services (collectively,
 our "Services").




Throughout this Policy we use the terms "personal information" and "PII" to describe information that can be
 associated with a specific natural person and can be used to identify that person. We do not consider personal
information or PII to include information that has been anonymized or aggregated so that it does not identify a
 specific natural person. If you give us PII on behalf of someone else (or someone else gives us PII on your behalf),
 the person providing the PII must have consent to do so from the person whose information is being provided to
 AcornAds.




AcornAds complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the
 U.S. Department of Commerce (collectively, the "Safe Harbor Principles") regarding the collection, use, and
 retention of personal information from European Union member countries and Switzerland. AcornAds has certified that
 it adheres to the Safe Harbor Principles of notice, choice, onward transfer, security, data integrity, access, and
 enforcement. To learn more about the Safe Harbor program, and to view AcornAds' certification, please visit http://www.export.gov/safeharbor/.




If you have any questions about this Policy, please contact us by email: support@acornads.com,
 or via mail at:




Privacy Officer
Acorn Ads
13359 North Highway 183 Suite 406-681
Austin, TX 78750




Please note that questions about our offerwall or missing credits should be emailed to our customer support team
 directly at support@acornads.com






How We Collect Information





We collect information from you in the following ways:




We may collect information from you, or someone acting on your behalf, when you interact with the Services. For
 example, you provide information to us when you:






• Create accounts for Services,


• Register for offers,


• Initiate or complete a transaction or offer,


• Click on our advertising,


• Elect to receive offers or other marketing communications,


• Request a coupon or other products,


• Complete a survey,


• Receive customer support,


• Purchase, download, or register to use products, or


• Apply for a job.






In addition, we may collect information through our Services. For example, we collect data through use technologies
 such as:






• Cookies and pixel tags,


• Location detection technology, such as GPS signals sent by a mobile device and IP addresses linked to a specific
 geographic location,



• HTTP headers,


• Unique Application Identifiers,


• Device identifiers,


• Activity log files, and


• Local storage, such as browser web storage (including HTML 5) and application data caches.






Click here for more details regarding our use of cookies and
 anonymous identifiers.




We sometimes obtain personal information from other sources, such as through mergers and acquisitions with other
 companies as well as through commercial arrangements with data brokers, business partners, and other sources. For
 example, a third party may provide us with your age, gender, or zip code. Information we receive from a third party
 is subject to your agreement with such third party. We may merge information we receive from third parties with
 information we have collected or will collect.

Some elements of AcornAds' Services such as events, websites, and offers may be co-branded and offered in conjunction
 with another company. For example, AcornAds may sponsor a website through which you can simultaneously purchase
 products and services from multiple AcornAds partners. If you provide information in these cases, both AcornAds and
 each company involved in the transaction may receive the information collected in connection with that transaction
 and thereafter may use the information according to each company's privacy policy and any other agreement each
 company may have with you.





Information We Collect





Information provided to us directly




You, or others acting on your behalf, may provide us with the following information:






• Your name, age, gender, physical address, email address, and phone number,


• The products and services you purchase, download or register to use and their value,


• Payment information such as credit card number, security codes, currency requirements, financial institution
 account number, or other payment credentials,



• Responses to survey questions,


• User preferences, product interests, communication choices, and other customer profile information, and


• Your resume or CV, references and background check information.






Information collected automatically




We use cookies and anonymous identifiers to collect certain types of information about your use of our Services such
 as:






• Internet Protocol Address,


• Browser type,


• Browser language,


• Operating system (of computer and mobile devices),


• User preferences,


• Screen resolution,


• Application identifiers,


• Traffic identifiers,


• Device type, identifiers or capabilities,


• Session ID or User ID,


• AcornAds Account,


• Referring site (site you visited before coming to our site),


• Date and time,


• Location of purchases made in connection with an offer,


• URL and content of pages visited or requested,


• Other browsing behavior, such as products and white papers downloaded,


• Domains,


• ISPs, and


• User Agents and


• Platform advertiser ID and tracking limitation indicators, IDFA, Google Advertiser IDs and corresponding Limit
 Ad Tracking flags.







We use location detection technology to determine your approximate location, nearby Wi-Fi access points, and cell
 towers.




When you use our Services we may automatically collect and store certain information in activity logs such as:






• Details of how you used our Services, such as your search queries,


• Internet protocol address,


• Content on the website viewed by you, and


• Page views within our Services.






Many internet browsers allow users to send a "Do Not Track" signal to websites they visit. Currently, there is no
 consensus on the meaning of "Do Not Track" or similar signals, and the Services have no mechanism to respond to such
 a signal.




Information collected with certain Services




Certain of our Services collect special information.




For example, if you use our Services in connection with a mobile device or mobile application, we may collect
 additional information about you, your use of your device, and applications on your device such as:






• Application version,


• System activity,


• Hardware settings,


• Total amount spent in an application,


• Total rewards earned in an application,


• Prior use of an application,


• User creation time,


• Length of session,


• Virtual currency balance, and


• Application level.






If you participate in surveys, we will collect the information you provide to us which may include sensitive
 information. Sensitive information includes your racial or ethnic origin, political opinions, religious or
 philosophical beliefs, trade-union membership(s), or data concerning your health or sex life. Your participation in
 surveys and any related disclosure of sensitive information is entirely voluntary.




If you participate in payment card-linked offers, we may collect your email address, payment card details, address,
 and information regarding your payment card purchases such as the date and time of your purchase, your returns of
 items purchased, the category of your purchase, and location of the store where you made a purchase.





How We Use Information We Collect




We use information we collect to conduct our business and improve our Services, develop new products and services,
 provide information and support for Services, better understand your needs and interests, personalize communications
 and advertising, and generally promote a quality experience for users of the Services. For example, we may use your
 information to:






• Communicate, interact and build our relationship with you,


• Customize the content, products, and services that are offered to you,


• Contact you with information about AcornAds and third parties,


• Process, fulfill, and follow up on transactions and requests for products, services, support, and information,



• Manage disputes between you and our partners,


• Create and maintain your AcornAds account and record your actions and transactions,


• Engage in market research and analysis,


• Measure, analyze and improve our products and services, the effectiveness of our Services, and our advertising
 and marketing,



• Consider your employment application,


• Retarget offers,


• Comply with legal requirements,


• Enforce our agreements, or


• Deter, detect, and prevent fraud and other prohibited or illegal activities.






We may link information we collect from multiple sources to provide better service to you, customize offers that may
 interest you, and to improve the Services.





How We Share and Disclose Information





We may share or disclose your information as follows:






• To corporate affiliates including any corporate entity controlling, controlled by, or under common control with
 AcornAds, Inc.,



• To our merchant partners, advertising partners, tracking partners, fulfillment partners, agents, service
 providers, and suppliers who are using your information on our behalf and/or in connection with an actual or
 potential transaction,



• Based on a good faith belief that such disclosure is necessary to protect the rights or safety of any person or
 entity,



• Based on a good-faith belief that disclosure is necessary to respond to judicial process, valid government
 inquiry, or is otherwise required by law,



• To an acquiring entity in the event that AcornAds or any of its assets are acquired or to a surviving entity in
 the event that AcornAds or any of its assets are involved in a merger,



• When posted by you or an authorized third party to our wikis, forums, blogs, message boards, chat rooms and
 other social networking environments, and



• To other third parties for purposes to which you have allowed or consented.







Safe Harbor Principles





Notice and Choice




AcornAds provides notice about the choices and means we offer you for limiting use and disclosure of your PII. Notice
 is provided in this Policy, in our web pages, and in other locations where we collect PII.




You can choose whether or not to provide your PII to us. If you choose not to provide PII, you can continue to
 interact with AcornAds, but you may be not be able to take advantage of certain offers, options, events and services
 that depend upon AcornAds having access to accurate PII. You can update your marketing communications preferences by
 logging into your AcornAds Online Account at www.AcornAds.com/login/,
 following the unsubscribe instructions you have received from AcornAds, or contacting AcornAds' customer support team.




Please note that while AcornAds offers you some control over what marketing communication you will receive, certain
 transactional, relationship, and legally required communications will not be affected by the choices you have made
 about marketing communications.




Onward Transfer




We will only share your PII with third parties if we determine in our good faith judgment that those third parties
 provide an adequate level of data protection to help ensure the security of your personal data, such as by agreeing
 to abide by industry codes of conduct, the Safe Harbor Principles, or the terms of a contractual confidentiality
 commitment.




Security




We take reasonable precautions including administrative, technical, and physical safeguards to protect the PII we
 have collected from loss, misuse, and unauthorized access, disclosure, alteration and destruction. In addition, we
 use standard security protocols and mechanisms to transmit sensitive data such as passwords and payment
 information.




These safeguards are designed to protect against, but are not a guarantee against, the loss, misuse and unauthorized
 access, disclosure, alteration, and destruction of your information.




Access and Accuracy




We aim to maintain the accuracy of your contact information and personal data. If you need to update or correct this
 please do so by logging into your AcornAds account.




You also may review or update your information by emailing support@acornads.com, or writing to:





Privacy Officer
Acorn Ads
13359 North Highway 183 Suite 406-681
Austin, TX 78750

Upon request, we will provide you with access to your personal information and the ability to correct, amend, or
 delete that information where it is inaccurate. We will make reasonable efforts to provide the requested information
 and/or incorporate the requested changes as soon as possible.




Before we provide access to any personal data or make any changes to it we may ask you to verify your identity or
 provide other details to help us respond to your request. We may keep a copy of information for our records. Access
 may not be granted where the burden or expense of providing access would be disproportionate to your individual
 privacy risks or where the rights of others would be violated.




Transfers




AcornAds is a global organization, with operations, processes, and systems that cross borders. We are certified under
 the Safe Harbor Principles and strive to comply with all applicable laws designed to protect privacy in the
 jurisdictions in which we do business.




If you choose to provide us with information, including PII, you understand that we may transfer it within AcornAds
 locations and systems in the United States or to the locations and systems of AcornAds' subsidiaries, joint venture
 partners, and third-party service providers around the world.





Children's Privacy





Use of our Services is only available to individuals who are of legal age to contract in their applicable
 jurisdiction. AcornAds' Services are not directed to children under 13 years of age. If that policy changes, we will
 obtain consent from a parent or guardian before we knowingly collect data from anyone under the age of 13.





Enforcement





AcornAds regularly reviews its compliance with this Policy. Please direct any questions or concerns regarding this
 Policy, AcornAds' treatment of PII, or AcornAds' compliance with the Safe Harbor Principles by email to support@acornads.com or in writing to:




Privacy Officer
Acorn Ads
13359 North Highway 183 Suite 406-681
Austin, TX 78750

If you have any complaints regarding our compliance with the Safe Harbor Principles, please contact us at the
 above.




As part of our participation in the Safe Harbor Principles, we have
 agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Principles. If you
 have any complaints regarding our compliance with the Safe Harbor Principles you should first contact us as provided
 above. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here fax to 415-520-3420, or mail to
 TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following
 information: our name, the alleged privacy violation, your contact information, and whether you would like the
 particulars of your complaint shared with AcornAds. For information about TRUSTe or the operation of TRUSTe's
 dispute resolution process, click here or request this
 information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be
 conducted in English. For human resources data we have agreed to cooperate with applicable Data Protection
 Authorities.





Changes to this Policy





Please note that this Policy may change from time to time. We will post any Policy changes on this page and, if the
 changes are significant or reduce your rights in any material manner, we will provide a more prominent notice. We
 will also keep prior versions of this Policy in an archive for your review.





Conclusion





We are committed to privacy and are involved in current industry initiatives to promote privacy and protect personal
 information. Our privacy practices will evolve to meet new requirements, standards, technologies, and customer
 preferences. We welcome your opinions and insightson this evolution.