Privacy Policy (Last modified: March 6, 2019)

We at SocialPath, Inc., doing business as SPS DGTL, a division of Y&L Consulting, Inc. (“SPS DGTL”, “Y&L Consulting”, “we,” “us,” or the “Company”) know that you care about how your personal information is used and shared, and we take your privacy very seriously. By visiting our website, registering with us or using any of our services, you are accepting and agree to comply with this privacy policy (the “Policy”). The column on the right provides a short explanation of the Policy and is not legally binding.

This Policy covers our treatment of personal information that we gather when you are on our website and when you use our services. This Policy does not apply to the practices of third parties that we do not own or control, or to individuals or entities that we do not employ or manage.

Information collected by us

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We collect information to make our Applications useful to you and to provide a customized experience.

We only collect personal information that is relevant to the purpose of providing software, including the Engage Platform and DGTL Local, and other services to you (collectively, the “Services”) through our website, www.spsdgtl.com, (“Website”) or mobile applications (collectively, the “Applications”). This information allows us to provide you with a customized and efficient experience. We collect the following types of information from our users:

Information you provide to us

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We collect the registration and user profile data that you provide for us.

We receive and store any information you enter through our Application or that provide to us in any other way. You may choose not to provide us with certain information, but then you may not be able to take advantage of the Applications or some of its special features.

Registration: To use some of our Applications you must complete a registration form. As part of this registration form, we require certain personal information, such as your name, phone number, address, location, email address. Our lawful basis for collecting personal information from you is to provide our services and to communicate with you through your consent when you register with us. Our collection of personal information from you is limited to information that we require in order to provide our Services to you.

Correspondence and comments: We may record your comments and opinions when you contact us directly (e.g. by email, phone, mail, or when you interact with our customer service) or when you respond to our surveys. We use this information to address your concerns and questions and to resolve any service issues you may have.

You have the right to edit, update, access, or transfer your personal information, or to delete your personal information if you are terminating your registration with us.

Third-party payment processor

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We use a third-party payment processor, Stripe, for all payments. We do not store credit card details and instead rely on Stripe.

We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any of your personally identifiable information or any of your financial information such as credit card numbers. Rather, you provide all such information directly to our third-party processor, Stripe, whose use of your personal information is governed by its privacy policy, which may be viewed at https://stripe.com/us/privacy.

Information we collect automatically

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Our servers collect information that we use to make our Applications and their features faster and better. We also collect geographic location data, which allows us to provide you a more customized experience.

Traffic Data. We and our authorized agents automatically receive and record certain "traffic data" on server logs from your browser including your IP address, cookie information, and the page you requested. We use this traffic data to help diagnose problems with our servers, analyze trends and administer the Applications. This does not involve collecting any of your personal information.

Device Identifiers. In addition to the "traffic data," we and our authorized agents may collect information about the device you're using to access our Applications, its operating system, unique device identifier and device settings such as language and crash data. The types of data we collect depends on the type of device you use and the system running on that device. This data is again used to help us diagnose problems with our Website and analyze trends. This data does not include any of your personal information.

Location Data. We may collect and use information regarding the geographic location of your devices. If the location data contains your personal information, then we will treat this location data in accordance with this Policy.

Many companies offer programs that help you to visit websites anonymously. While we will not be able to provide you with a personalized experience if we cannot recognize you, we want you to be aware that these programs are available.

Communications

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We will send you emails based on your profile settings. From time to time, we may send emails to all our users.

We are very concerned about your privacy and we will never provide your email address to a third party without your explicit permission, as detailed in the "Sharing Your Information" section below. We may send out emails with Company-related news, products, offers, surveys or promotions. You may also receive notification emails from us that inform you of actions that have been performed on the site. We send these emails to you based on receiving your consent at registration. If you do not want to receive email from us, please visit the “Email Preferences” section of your user profile and/or follow the “unsubscribe” instructions contained in each email message. However, please note that in all cases you will continue to receive all system emails (e.g. those regarding forgotten user passwords) and legal notices (e.g. updates to our policies) from us unless you terminate your registration altogether.

Cookies and Web Beacons

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To remember you, our system will give you a cookie. It's safe, but you can’t eat it. We also use web beacons. We may use third-party services that help us analyze how our Website and Applications are used. These third-parties also use cookies to collect information about our online visitors and how they interact with our ads.

These cookies aren’t meant to be eaten, but they do provide you with some good things. Our “cookies” are alphanumeric identifiers that we transfer to your computer's hard drive through your Internet browser to enable our systems to recognize your browser and tell us how and when pages in our Website are visited and by how many people. We also use web beacons to tell us how our Website is being used and what pages are being visited. Our cookies and web beacons do not collect personal information.

Google Analytics We also use the AdWords feature of Google Analytics and, accordingly, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Website. This means that vendors including Google will display our promotional material on other sites you visit across the Internet.

You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager.

To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout, to enable you to opt-out of Google’s programs.

Hubspot Our website uses Hubspot, a third-party company, for marketing automation. Hubspot sets cookies that track a user’s interaction with our site, including browser-provided information such as inferred region, IP address, and return visits. Users remain anonymous unless the user has provided personal information through the submission of a form or clicks through to our Website from a link in a Hubspot email. For more information on Hubspot cookies and what they are used for, see Hubspot’s Privacy policy at https://legal.hubspot.com/privacy-policy.

Facebook We use social plug-ins Facebook Inc.. The plug-ins can be recognized by way of the Facebook logo or the supplement “Facebook Social Plug-in.” For example, if you click on the “Like” button or leave a comment, the relevant information is transmitted directly from your browser to Facebook and stored there. Furthermore, Facebook makes your likes public for your Facebook friends. If you are logged into Facebook, it can assign the invocation of our Website directly to your Facebook account. Even if you are not logged in or don’t have a Facebook account, your browser sends information (e.g. which web pages you have called up and your IP address), which is then stored by Facebook. For details about handling of your personal data by Facebook and your related rights, please refer to Facebook’s privacy policy at http://www.facebook.com/policy.php. If you do not want Facebook to map data collected about you through our Website, you must log out of Facebook before you visit our Website.

Facebook We use the Facebook Pixel developed by Facebook, Inc., 1601 S. California Ave, Palo Alto, CA 94304. This feature makes it possible to track the behavior of users who have clicked on a Facebook ad and been directed to the website of the provider in question. The effectiveness of Facebook ads can then be assessed for statistical and market research purposes, which in turn can help optimize future advertising measures. The data we obtain through this process is anonymous, meaning it gives us no means of tracing the identity of any user. Facebook can then use the data for its own advertising purposes in line with its data usage guidelines https://www.facebook.com/about/privacy/. As a result, Facebook and its partners can insert ads both on and outside of Facebook.

LinkedIn We use the LinkedIn Insight Tag provided by the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about users interacting with our LinkedIn advertisements. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until it is deleted, or the cookie expires. With the help of the LinkedIn Insight Tag we can analyze the success of our campaigns within the LinkedIn platform or determine target groups for them based on the interaction of the users with our website. If you are registered with LinkedIn, it is possible for LinkedIn to associate your interaction with our online services with your user account.

You can permanently opt out the LinkedIn Insight Tag tracking at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. For more information, visit the LinkedIn Privacy Policy at https://www.linkedin.com/legal/privacy-policy.

The "help" portion of the toolbar on most browsers will also direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use some of our best features. Some of our business partners, like our advertisers, may use cookies on our Website. We have no access to, or control over, these cookies.

Third-party analytic services

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We use third-party analytics services that help us better understand usage trends, which we use to make decisions. These tools don't collect personal information, and all information collected is used in accordance with this Policy.

We use services like Google Analytics and/or Amplitude to help analyze and understand how our Applications are used, so that we can make our products more helpful to you. These tools capture data about how individual users are using our Applications. This includes event logs, device type and device configuration settings such as language, crash data and other data, but never includes personal information. These third-party services treat the analytics data in accordance with this privacy policy. We do not disclose your personal information to any third parties through our use of these services.

Sharing your information

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We do not sell your information to anyone. However, we may share information so that we can provide you our Services, and we may share information where required by law. We may also share information with third-parties that help us provide our Services to you. Sometimes we aggregate user data anonymously to understand our customer base better.

Your trust is important to us. Rest assured that we will not rent or sell your personal information to anyone and that we will share your personal information only as described below

Our Personnel. Our personnel and authorized consultants and/or contractors may have access to user information if it is necessary in the normal course of our business, but they will have contractual obligations to comply with this Policy.

Business Transfers. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Company, or substantially all of its assets, were acquired, user information would be one of the assets that would be transferred. Any transferee would still be obligated by law to comply with this Policy.

Protection of the Company and Others. We may release personal information when we believe in good faith that the release is necessary for us to: comply with a law; enforce or apply our Terms of Use and other policies; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Service Providers: We may share user information as well as information from tools such as cookies, log files, device identifiers and location data, with third-parties that help us provide services to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary for us to provide our services. We require Services Providers to protect your data in a manner consistent with this Policy and to limit the use of such information to the performance of services for us. We may also remove parts of data that can identify you and share anonymized data with Service Providers, including combining your information with other information in a way that it is no longer associated with you.

Data Storage: Your encrypted personal information is stored on servers provided by a third-party cloud-based service provider that protects and stores your data in a manner that is consistent with this Policy.

With Your Consent: Except as noted above, we will contact you when your personal information is shared with third parties or used for a purpose incompatible with the purpose(s) for which it was originally collected, and you will be able to opt out to prevent the sharing of this information.

Aggregated personal data. In an ongoing effort to better understand and serve the users of the Applications, we may conduct research on our customer demographics, interests and behavior based on personal data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Keeping your information secure

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Your account is protected by an encrypted password. We keep it secret (and secure); you must keep it safe. Our employees may not access your account unless required to do a specific job.

We take reasonable steps to protect the personal information provided through the Applications from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, including by protecting your information behind a firewall within a perimeter network and encrypting your information during transmission.

However, no Internet or email transmission is ever fully secure or error free. You can help protect your information against unauthorized access by logging off once you have finished using a shared computer and by keeping your password private and secure.

Only employees who need personal information to perform a specific job (for example, a customer service representative) are granted access to it. All of our employees are kept up to date on our privacy and security practices.

Ways you can control our use of your information

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You can choose not to share information with us, but your experience of the site may be limited. You will receive all system emails until your account is deleted.

As stated previously, you can always opt not to disclose information, but then you may be unable to use certain features of our Applications.

By visiting your user profile, you can correct, amend, add or delete personal information in the Applications.

If you do not wish to receive email from us, please visit the settings of your user profile and/or follow the instructions contained at the bottom of the unwanted email message. However, please note that you will continue to receive all system emails (e.g. those regarding forgotten user passwords) and legal notices (e.g. updates to our policies, including this one) from us unless you terminate your account with us.

As explained earlier, the "help" portion of the toolbar on most browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. Please note, however, that if your browser does not accept cookies, you will not be able to take advantage of some of our Applications’ features.

Children under 18 years of age

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You are not allowed to register or use our Applications if you are under 18.

You must be 18 years or older to register to use our Applications. As a result, we do not specifically collect information about children. If we learn that we have collected information from a child under the age of 13, we will delete that information as quickly as possible.

Changes to this privacy policy

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This Policy may change, but we’ll tell you if it does.

We may amend this Policy from time to time, at our sole discretion. Use of information we collect now is subject to the Policy in effect at the time such information is collected. If we make changes to the Policy, we will notify you by emailing you at the current email address in your user profile and by posting an announcement on our website so you are always aware of what information we collect, how we use it, and under what circumstances if any, it is disclosed.

Conditions of use

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Using our Services is subject to our Terms of Use and this Policy.

If you decide to use our website or Services, your use and any possible dispute over privacy is subject to this Policy and our Terms of Use, including limitations on damages, arbitration of disputes, and application of Texas law.

Questions

If you have any questions, comments or requests relating to this Policy, please send an email to info@spsdgtl.com.

Effective date of this policy

This Policy is effective as of March 1, 2019