Effective Date: 3/28/2019
Summary – Policy Overview
This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.
2. What Categories of Information We May Process.
Summary – Categories of Information We May Process.
We may process: your personal information, demographic data, your contact details, records of your consents, purchase details, information about your interactions with our content or advertising, credit card or other financial information regarding purchases, and your person identification and any views or opinions you provided to use.
We may also Process information about you from the use of our Services, such as the device you’re using, internet service provider, device operating system.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identified.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, destruction.
We may Process the following Personal Information about you:
● Personal data & Profile: your name, e-mail, phone number, address, payment or banking information, photograph, and public social media handles or profile(s).
● Personal Identification: your state issued personal identification card to verify age, location, and identity.
● Demographic information: gender, age/date of birth, nationality and language preferences.
● Consent Records: records of any consents you may have given, together with the date and time, means of consent and any related information.
● Location information: location data that describes that precise geographic location of your device(s) used to access the Services. (“GEO Location Data”)
● Purchase and Payment Details: records of purchase and prices, invoice records, payment records, billing address, payment method, cardholder or account holder name, payment amount and payment date.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
● Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
● Browsing history including the websites or other services you visited before and after interacting with the Services.
● Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
● Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
● Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
● Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
● Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
● Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business.
Children. The Services are not intended for use by children, especially those under 18. No one under the age of 18 should provide any Personal Information or use our Services. Minors under the age of 18 and in some States minors under the age of 21, are not permitted to utilize or make purchases through the Services. If, notwithstanding these prohibitions, your children disclose information about themselves consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 18, we will delete that information immediately.
3. How We Collect Or Create Information.
Summary – Collection and Creation of Information
We may collect or obtain information about you; directly from you, in the course of our relationship with you; when you make your Personal Information public; when you use any of our Services when you visit our Services when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive information about you from third parties. We also create information about you, such as records of your interactions with us. OP24 is not responsible for Personal Information you volunteer about yourself in public areas other Services. This Policy does not cover the practices of third parties who may provide information about you to OP24.
Collection of Information: We may collect information about you from the following sources:
● Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, giveaway, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
● Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us). This includes your state issued personal identification card.
● Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your
social media profile(s) if you make a public post about us) or through our forums or communities on the Services.
● Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
● Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive information about you from the relevant third party.
● Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third-party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, Instagram, Pinterest, LinkedIn, etc.). If you use a third-party connection or log-in (e.g., Facebook Connect, Twitter, Instagram, Pinterest, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third-party services or other information available about you or collected from you on those services.
OP24 is not responsible for information you voluntarily disclose about yourself in the public facing areas of the Services. We discourage users from posting such Personal Information in this fashion.
To request removal of your Personal Information please contact at legal(at)instafap.com, and provide your name, address, and any other information required to locate your account. In some cases, we may not be able to remove your Personal Information, in which case we will let you know why we are unable to do so.
4. Purposes for Which We May Process Your Information.
Summary – Purposes for Which We May Process Your Information
We may Process information for the following purposes; providing Services to you; communicating with you; providing advertising to you on the Services; analyzing engagement with our audience; observing user engagement and purchase activity across the Services; offering business-to-business lead generation; marketing our services to current and prospective customers and marketing partners; financial management, security of our systems, conducting investigations where necessary, compliance with applicable law; and improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:
● Provision of the Services to You: providing the Services to you from OP24 or its partners including the offering of contests, posting of your personal testimonial alongside other endorsements, display of your personal reviews of products or services, management of your account, and customer support and relationship management.
● Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the
Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
● Surveys: engaging with you for the purposes of obtaining your views on our Services.
● Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out below.
● Advertising: providing advertising based on your interests and interactions with the Services, including using the information to serve you advertisements on the Services
● Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service.
● User Engagement and Purchases: tracking purchase traffic and activity across the Service, including a review of your browsing history (if available); provision of analytics and measurement of the cost of traffic against money being made.
● Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular merchant’s site to offer coupons and other offers that are relevant to your shopping experience; the offering of coupons via SMS messages if a mobile phone number is provided.
● Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by OP24 B2B, whereupon your contact information will be shared with our customer.
● Marketing to Customers: We may market to current and prospective customers who have indicated an interest in doing business with, or have previously conducted business with, OP24 in order to further generate and promote our business.
● IT Administration: administration of OP24’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
● Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
● Financial Management: general business and financial management purposes, including economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
● Investigations: detecting, investigating and preventing breaches of policy, and criminal offenses, in accordance with applicable law.
● Legal Proceedings: establishing, exercising and defending legal rights.
Direct Marketing: We may process your information to contact you via, e-mail, telephone, direct mail, SMS or other methods of communications developed now or in the future, to provide you with information regarding Services that may be of interest to you. We may send information not you regarding the Services, upcoming promotions, and other information that may be of interest to you, using the contact details that you have provided to use and always in compliance with applicable law. You may opt-out of direct marketing at any time via your user profile account or by the method provided in each communication.
Opting out of any direct marketing does not mean will no longer contact you. OP24 may still continue to contact you to the extent necessary for purposes of any other Service you have requested or for e-mails you’ve signed up for and not opted out of yet.
5. Cookies, Similar Technologies, and Online Behavioral Advertising.
Summary - Cookies, Pixels and Similar Technologies.
OP24 utilizes cookies, pixels, and similar technologies on its Services, to process your information. Certain tracking technologies assign a unique identifier to you, and related information about your use of the Services to third parties tracking partners for the purpose of learning more about you so we can provide you with relevant content and advertising. We also use these technologies to analyze trends administer the Services, collect and store information such as user settings, anonymous browser identifiers, and video viewing history, supplement to our server logs and other methods of traffic and response measurement.
You have the right to choose whether or not to accept or remove cookies. However, they are an important part of how our services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the services.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to require your acceptance of each individual cookie. To do so, please follow the instructions provided by your browser, which are usually located within the “Help” or “Preferences” menu. Please note that removing or rejecting browser cookies does not necessarily affect third party flash cookies, which may be used by us, affiliates, or third parties in connection with our services. To delete or disable flash cookies please visit this site (https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-fl…) for more information. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://youradchoices.com/.
For mobile users, you usually have controls in your device’s Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like OP24 and our advertising service providers. For information on controlling your mobile choices, you can visit www.networkadvertising.org/mobile-choices.
What Cookies Do We Use?
Below is a list of each category of cookies we use and why we use each cookie.
● Essential Cookies or Strictly Necessary Cookies: These cookies are essential to the Service in order for you to move around the Service and to use its features. Without these cookies, certain features could not function. No information about your browsing habits is gathered by these cookies.
● Functional Cookies: These cookies remember how you prefer to use the Service and enable us to improve the way the Service works. We can remember your settings and help provide you with ads. Functional Cookies are persistent cookies that the Service remembers when your computer or device comes back to that Service.
● Analytics Cookies: Analytics Cookies allow us to improve our services by collecting information about your use of the Service. We use these cookies to help improve how the website works. For example, Analytics Cookies show us statistics, which are the most frequently visited pages on the Service, help us record any difficulties you have with the Service, and show us whether our advertising is effective or not. We can’t identify you personally through the use of these cookies, but third parties who provide these cookies may be able to.
● Behavioral Advertising Cookies: Behavioral Advertising Cookies are used to deliver relevant advertisements to users both on and off the Service. We analyze what pages you visit on these sites, what products or services you view, and whether you view or click on ads that are shown to you. We may also use a cookie to learn whether someone who saw an ad later visited and took an action on the advertiser’s site. We use this information to send you interest-based ads and may also share this information with third parties. Similarly, our partners may use a cookie to determine whether we’ve shown an ad and how it performed, or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off the Service, such as after you have visited a partner’s site or application.
● Geo-Location Information: Some devices allow applications to access real-time location-based information (for example, GPS). Some photos or other content you place within the Service may contain recorded location information. We may use this information to optimize your experience. Also, some of the information we collect from a device, for example, IP address, can sometimes be used to approximate a device’s location.
In addition to cookies, we may also use other similar tracking technologies on our services, such as pixel tags (also known as clear GIFs, pixels or web bugs), web beacons, eTags, and local storage. We use these technologies to do things like store user settings video viewing history, gather demographic information about our user base as a whole or track users’ movements around the Service, to serve interest-based ads, or to improve our understanding of things like site traffic, visitor behavior and promotional campaigns. Pixel tags are small blocks of code installed in or on a web page, mobile app, or advertisement and are a method for passing information from your device to a third party website. Web beacons are electronic files that allow a website to count users who have visited that page or to access certain cookies. Local storage, such as HTML 5, allows a website or mobile app to store and retrieve data on an individual’s device. eTags are tags used to analyze trends by us and our commerce partners.
6. What is the Lawful Basic for Processing Personal Information.
Summary – Lawful Basis for Processing Your Information
We may Process your information where: you have given consent, the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interest of any individual; or where we have a valid legitimate interest in the Processing.
In Processing your information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal basis, depending on the circumstances:
● Consent: We may Process your information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
● Contractual necessity: We may Process your information where the Processing is necessary in connection with any contract that you may enter into with us;
● Compliance with applicable law: We may Process your information where the Processing is required by applicable law;
● Vital interests: We may Process your information where the Processing is necessary to protect the vital interests of any individual; or
● Legitimate interests: We may Process your information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
7. What Information We Disclose to Third Parties.
Summary – Disclosure of Information To Third Parties
We may disclose your information to legal and regulatory authorities; parties who Process your information on our behalf (‘Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, any purchaser of our business, and any third party advertising, plugins or content used on the Services.
We may disclose your information to other parties, for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
● legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
● outside professional advisers (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
● third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world.
● third party background check services to validate your identity as required by your States laws before making a purchase or using the Services.
● any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
● any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
● any relevant third party provider, where our Services use third-party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
8. Data Minimization, Retention and Removal
Summary – How We Minimize Collection of Your Data and How Long we Keep and Remove it.
We take every reasonable step to limit the volume of your information we Process to what is necessary to provide the Services. Your information is only retained for as long as needed, at which time it is removed from our systems. Additionally, you may request to have your data removed from our systems, is reasonable and it does not interfere with providing services to you.
California Residents may request a report detailing what information we’ve retained in systems about them.
OP24 takes every reasonable step to ensure that your information that we Process is limited to the data reasonably necessary in connection with the purposes set forth in this Policy or as required to provide you services or access to the Services.
OP24 retains your user profile and account information for as long as you maintain your user account. OP24 may retain transaction, location, usage, and other information for one year from the date of termination in connection with regulatory, tax, or other requirements in place in which its operations. Thereafter, OP24 shall delete or anonymizes such information in accordance with applicable laws.
California Residents. In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set forth in section 9 below.
EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure, and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us in writing via the contact details set forth in section 9 below. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
Your Newsletter and Email Subscriptions. You can opt-out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
9. Contact Details.
Operation 24 LLC
Attention: Legal Department
PO Box 45
Boca Raton FL 33432
Our Data Protection Officer may be contacted at legal(at)instafap.com
10. Modifications and Updates