YOUR PRIVACY IS IMPORTANT

This Privacy Policy (“Policy”) describes the manner in which PushFlyer, LLC, (“PushFlyer”) handles personal information collected from individuals (“you” or “users”) by PushFlyer through PushFlyer website(s) or in connection with PushFlyer’s delivery of services to its customers. In this Policy, the term “personal information” refers to information relating to an identified or identifiable natural person.

This Policy applies to PushFlyer websites that directly link to this Policy when you click “Privacy Policy” in the website footer. Please refer to the privacy policies of any linked third party website to learn how the operators of those websites collect and use information that is gathered through those websites.

Information Categories

PushFlyer collects and uses personal information both on its own behalf and in connection with its delivery of services to its customers. This Policy is divided into separate sections to distinguish these different categories of information.

Regarding Information Collected or Used by PushFlyer on Its Own Behalf

Notice

PushFlyer will notify you about the purposes for which it collects and uses information about you, how to contact PushFlyer with inquiries or complaints, the types of third parties to whom it discloses personal information, and the choices and means the organization offers individuals for limiting its disclosure. This notice will be provided by this Policy, which is available from PushFlyer’s home page so that you may review it before you disclose personal information to PushFlyer.

Choice

PushFlyer provides you with the right to opt-out whether your personal information is disclosed to a third party, or used for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you. This Policy clearly describes the ways that PushFlyer uses and discloses your personal information. If you wish to opt-out at any time, you may do so by contacting us at [email protected]. In addition, there is an opt-out feature located in the footer of all unsolicited PushFlyer email communications.

Personal information gathered

The PushFlyer website has various features which allow those interested in PushFlyer and its services to obtain more information about PushFlyer, such as by subscribing to a PushFlyer Newsletter, viewing a webinar, obtaining a free trial of a PushFlyer service, purchasing a subscription to a PushFlyer service, participating in a promotional event, or requesting a white paper. PushFlyer asks those requesting such information to provide PushFlyer with certain personal contact information that PushFlyer may use to follow up with those interested in its services. The information PushFlyer may collect includes first and last name, company or organization, title or position within the company or organization, postal address, phone number, email address, and credit card information. PushFlyer stores this information and uses this information internally to invoice and provide support to its customers and in addition for PushFlyer’s own marketing purposes.

Technical information gathered online

PushFlyer may employ web tracking technologies, such as log files and web beacons, in order to collect certain technical information about the operation of its websites and the behavior of visitors to the websites. The information collected may include: The URL of the site that you came from before visiting PushFlyer’s website; your computer’s IP address; the browser you are using; the pages that you visit on the PushFlyer website; search terms that were used to reach the PushFlyer website. PushFlyer websites also use cookies that track anonymous traffic data and to authenticate users and keep track of users’ sessions. Some cookies are used to allow users to enter the portions of the PushFlyer website reserved for registered PushFlyer customers or to govern survey voting. All cookies, except those used for survey validation, expire within several hours after a period of idle use. PushFlyer may use cookies and web-tracking technologies to associate your online behavior with your personal information and use that information internally for PushFlyer’s marketing purposes.

Onward Transfer

PushFlyer does not disclose personal information submitted to PushFlyer to any third party, except as follows:

  • PushFlyer may disclose personal information to subcontractors engaged by PushFlyer to perform services on its behalf, such as fulfillment houses that send marketing information on PushFlyer’s behalf. Any subcontractors to whom personal information is disclosed are subject to written agreements of confidentiality. Any subcontractor that receives any personal information of individuals resident in the European Union is either itself subject to EU data privacy law, subscribes to the Safe Harbor Principles or another adequacy finding, or has entered into a written agreement with PushFlyer requiring that such third party provide at least the same level of privacy protection as the Safe Harbor standards.
  • PushFlyer reserves the right to disclose personal information if required by law enforcement authorities, subpoena or other court order, or other governmental authority, and (to the extent permitted by law and the Safe Harbor principles) to the extent necessary to protect the legal rights and personal safety of PushFlyer and its employees and agents.

Security

PushFlyer maintains reasonable precautions designed to ensure the security of personal information covered by this Policy and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. PushFlyer has a written data security policy that describes the policies and procedures by which data security is to be maintained. Although PushFlyer makes every effort to ensure the security of its customer information, no data transmission over the Internet can be guaranteed to be 100% secure.

Data Integrity

PushFlyer takes reasonable steps to ensure that personal information it collects is reliable for its intended use, accurate, complete and current. PushFlyer does not use personal information in ways that are incompatible with the purposes for which the information was disclosed.

User Access to Personal Information

PushFlyer allows you access to personal information held about you and allows you to correct, amend or delete that information is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to your privacy. If you have submitted personal information to PushFlyer, and you wish to obtain access to such information in order to review, amend, or delete that information, you should contact PushFlyer by emailing us at [email protected] PushFlyer reserves the right to confirm your identity before providing access.

Regarding Information Received or Used by PushFlyer on Behalf of Its Customers

PushFlyer’s services allow PushFlyer’s customers to send email communications to their customers (“end-customers”). In order for these services to be delivered, PushFlyer’s customers upload certain personal information about their end-customers to PushFlyer’s servers. Such information includes email addresses, and may also include other information such as names and addresses of the end-customers to whom the email communications will be sent. PushFlyer does not control the categories of information that a PushFlyer customer may choose to upload to PushFlyer’s servers. PushFlyer stores this information on its servers on behalf of its customers and acts merely as a data processor with respect to this data. This information is controlled by the PushFlyer customer on whose behalf the information is stored.

PushFlyer uses personal information about end-customers stored by PushFlyer customers solely for the purposes of delivering services to PushFlyer customers. This includes sending email communications to the end-customers and providing analytical reports to PushFlyer customers relating to PushFlyer services. PushFlyer uses web tracking technologies to track the online behavior of end-customers as they interact with the electronic marketing materials sent on PushFlyer customers’ behalf. PushFlyer associates such online behavior with personal information and provides this data to the applicable PushFlyer customer; for example, if end-customer clicks on a particular product featured in an email communication sent by PushFlyer, the PushFlyer customer may receive a report from PushFlyer identifying the product interest of its end-customer.

Choice

Because information held on behalf of PushFlyer customers is controlled by PushFlyer customers, PushFlyer cannot delete or modify that information. If you wish to opt-out with respect to the information stored or used by PushFlyer customers, you should contact the applicable PushFlyer customer directly.

Disclosure of Information stored by PushFlyer on behalf of PushFlyer’s customers

PushFlyer does not disclose any end-customer personal information stored on behalf of its customers to any third party except to a) the PushFlyer customer on whose behalf the information is stored, b) to third parties that the PushFlyer customer has agreed, in writing, may receive such information, and c) to PushFlyer subcontractors performing services on behalf on PushFlyer. Any subcontractor to whom personal information is disclosed is subject to written agreements of confidentiality. Any subcontractor that receives any personal information of individuals resident in the European Union is either itself subject to EU data privacy law, subscribes to the Safe Harbor Principles or another adequacy finding, or has entered into a written agreement with PushFlyer requiring that such third party provide at least the same level of privacy protection as the Safe Harbor standards. Information stored on behalf of any PushFlyer customer is under the control of the applicable PushFlyer customer.

Security

PushFlyer maintains reasonable precautions designed to ensure the security of end-customer personal information covered by this Policy and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. PushFlyer has a written data security policy that describes the policies and procedures by which data security is to be maintained. Although we make every effort to ensure the security of end-customer information, no data transmission over the Internet can be guaranteed to be 100% secure. PushFlyer Customer accounts are password-protected so that only PushFlyer or the applicable PushFlyer customer has access to personal information of end-customers. It is incumbent on the PushFlyer customer not to divulge their password to anyone. PushFlyer will never ask for a customer’s password in an unsolicited phone call or in an unsolicited email.

Data Integrity

PushFlyer is not responsible for the data integrity of data held by PushFlyer on behalf of PushFlyer customers, because PushFlyer acts solely as a data processor for such customers.

Access

PushFlyer cannot offer end-customers access to information stored by PushFlyer on behalf of its customers. Such information is under the control of the relevant PushFlyer customer, and you should contact that PushFlyer customer if you wish to obtain access to any personal information about you which is held by them.

GENERAL PROVISIONS

Enforcement of this Policy

If you have a question, comment or complaint about this Policy or enforcement of this Policy, please address your concern to PushFlyer at [email protected], or send correspondence to the following address:

PushFlyer, LLC
2029 Century Park East
Los Angeles, CA 90067 USA
Attention: Managing Director

PushFlyer will investigate your concerns promptly and will respond to your correspondence within thirty (30) days after we receive it. PushFlyer will provide you with a clear explanation of any decisions made with respect to your request. If you are not satisfied with the manner in which PushFlyer dealt with your privacy concern, you may use the external recourse mechanism described below.

Verification

PushFlyer conducts an annual self-assessment to verify that this Policy is accurate, comprehensive, prominently displayed, completely implemented, accessible and conforms to the Safe Harbor Principles, and to confirm that employee training and appropriate compliance procedures are in place.

Changes to Privacy Policy

Changes to this Policy will be posted in this section. This way you will always have a clear understanding of what information is collected online and offline, how it is used, and the choices you have. Your personal information will only be used in accordance with the version of the Policy that is in place at the time that you provided your information unless you provide your consent to do otherwise.