Privacy Policy

We respect your privacy.

Your privacy is critically important to us.

At Tinuiti we have a few fundamental principles:

We don’t ask you for your personal information unless we truly need it and the only reasons would be for you to contact us to hear about our services, join our newsletter, download or sign up to receive content, offer our services, or join our team (we can’t stand services that ask you for things like your gender or income level for no apparent reason).

We share your personal information as little as possible, including some co-marketing and co-sponsoring events, and to comply with applicable laws, develop, enhance or modify our services or protect our rights.

We don’t store personal information on our servers unless required for the on-going operation of one of our services or as specified on our website forms.

Tinuiti Inc. (“Tinuiti,” “we,” “us,” or “our”) operates www.tinuiti.com, www.CPCStrategy.com, www.theortegagroup.com, www.blisspointmedia.com, www.prospectpointmedia.com, their subdomains, and all portals, products, services, events, and interactive features, or other services controlled by us that post a link to this Privacy Notice (the “Site”). It is Tinuiti’s policy to respect your privacy regarding any information we may collect while operating the Site. This Privacy Notice governs information that we collect from you on the Site, through interactions with Bliss Point Media (“Bliss Point”), our digital streaming and broadcast media advertising arm, and other online and offline communications with our personnel. We refer to all of the above as “Services.” By using the Services, you agree to the terms and conditions of this Privacy Notice. This Notice only applies to Personal Information and other information collected by us from: (i) visitors to the Site; (ii) users of our Services; and (iii) job applicants. If you have questions about this Privacy Notice, contact us at [email protected].

Tinuiti is a data controller for data collected on the Site.

EFFECTIVE DATE: JANUARY 18, 2022

Below is our privacy policy which incorporates these goals.

Click on one of the hyperlinks to take you directly to that section of the notice.
  1. Personal Information Collected
  2. Use of your information
  3. How We Share and Disclose Your Information
  4. International Transfer of Data
  5. Third-Party Links
  6. Choice and Individual Rights
  7. Your Rights Under the General Data Protection Regulation (“GDPR”)
  8. Your California Privacy Rights
  9. Security
  10. Sensitive Data
  11. Our Policy on Children’s Information
  12. Privacy Notice Changes
  13. Accessibility
  14. Contact Us

1. PERSONAL INFORMATION COLLECTED

1.1. Information You Provide Directly To Us

As you interact with the Site or Services, Tinuiti may ask you to provide us with certain personal information that can be used to contact or identify you (“Personal Information”) via the online chat function and webforms or inputs/uploads on the Site, and through webinars, events, telephone calls, letters, emails and other communications with you. Personal Information includes, but is not limited to:

  • Contact and account information. We may collect information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers, job title and profession, company name and URL;
  • Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on the Site, App or Services (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, Twitter and Pinterest) or posted on social media pages (such as our social media page or other pages accessible to us);
  • Employment information. If you apply for employment with us, we may collect information such as your current or past employment or educational information, date of birth, race/ethnicity, gender, veteran and/or disability status, as well as references and referrals provided to us in connection with your employment applications; and/or
  • Other information. We may collect other information that could reasonably be used to identify you personally or identify your household or device.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Site or Services.

1.2. Information Automatically Collected from Website

Like most website operators, Tinuiti collects information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Tinuiti’s purpose in collecting non-personally identifying information is to better understand how visitors use the Site.

Tinuiti may also collect potentially personally identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on blogs, if available. Tinuiti only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally identifying information as described below.

For location information, some of our Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). To the extent you use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information can come from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, or promotions may be limited or disabled.

1.3. Information Received Directly from Clients

Tinuiti and Bliss Point may receive data, including personally identifiable or aggregate data, from our clients that we process per a contract in place with these clients. We do not have a direct relationship with these individuals and are acting as a service provider to our clients in this instance. While we maintain this data, we are only permitted to use it to provide the services we are contracted to provide.

1.4. Information Collected Related to Bliss Point Services

In connection with services provided by Bliss Point and the Site, Bliss Point may have collected the following categories of Personal Information in the past twelve months:

  • Public IP addresses, from content publishers, marketing partners, our clients, and users of the Site. A Public IP address is a unique number associated with each device that connects to the internet. When there are multiple devices that connect to the internet through a single computer network, the network displays a single Public IP address for all of the devices. In that situation, we may collect the single Public IP address and do not collect the IP addresses for the individual devices.
  • User Agent information, (i.e., information about a consumer’s web browser, software, device, and operating system) from content publishers, marketing partners, and users of the Site.
  • Cookies”, from content publishers and from users of this Site. Cookies are small files that are created when a consumer visits a website to help improve the functionality of the website and to improve the consumer’s experience using the website. Cookies can help to keep track of a consumer’s movements within the website; help consumer’s resume where they left off on a website; help consumers remember their login information, theme selection, and preferences; and help to enable other customization functions.
  • Mobile Advertising IDs, from content publishers and from users of this Site. Mobile Advertising IDs are identifying numbers assigned to a consumer’s mobile device by the device’s operating system.
  • User identifiers, from our clients and from content publishers. A user identifier is a unique string of numbers that may be assigned to a consumer when the consumer visits a website.
  • Data about consumers’ transactions with our clients, which we collect from our clients. Such data may include information about the number of purchases, items purchased, and cost of those purchases, but does not include things like name, email or Personal Information from the transaction.
  • Data about consumers’ behaviors on our clients’ websites, which we collect from our clients. Such data may include information about whether a consumer performed certain actions on the website – for example, whether a consumer clicked certain links or visited certain pages.
  • Geolocation data, which we collect from a commercial subscription database.

1.5. Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Tinuiti and Bliss Point uses cookies to help us identify and track visitors, their usage of the Site, and their website access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Site, with the drawback that certain features of the Site may not function properly without the aid of cookies.

1.5.1. What Kinds of Cookies and Tracking Technologies Do We Use?

The Site may use Strictly Necessary Cookies, Performance Cookies, Functional Cookies, Targeting Cookies and Social Media Cookies. Any of these may be first-party cookies or third-party cookies, persistent or session.

  • Strictly Necessary Cookies: These are cookies without which you would not be able to use this Site. For example, Strictly Necessary Cookies adjust the Site data transmitted to match your Internet connection, get you to the secure versions of the Site, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Site will not work. Strictly Necessary Cookies do not store any Personal Information.
  • Performance Cookies: We use these cookies to count visits and traffic sources, to measure and improve Site performance. They help us to know which pages are the most and least popular and see how visitors move around the Site. Performance Cookies do not store any Personal Information. Specifically, for analytics providers, we use Google Analytics and Marketo. Google Analytics, which is a web analytics service offered by Google, and Marketo, a third party inbound marketing and sales software, track and report website traffic. Both services use the data collected to track and monitor the use of our service. Google Analytics shares this data with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. You can also request access, correction, updates or deletion of your Personal Information we collect via Marketo. If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time by contacting us or clicking on the “unsubscribe” link located at the bottom of our email communication. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. To exercise these rights, please contact us at [email protected]. For more information on the privacy practices of Marketo, please visit their Privacy Policy: https://www.marketo.com/company/trust/security/
  • Functional cookies: These cookies allow the Site to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
  • Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the Site and other websites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. To better serve users’ preferences, we have partnered with the Digital Advertising Alliance (http://youradchoices.com); by visiting their website, you can learn more about their members who deliver tailored online ads and your choices to opt-out of receiving them. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests. We work with Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on the Site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Google AdWords/Analytics: Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/

We may also use third-party Service Providers to show advertisements, which may include targeted advertisements on a third-party website after you have visited the Site. We and the third-party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to the Site. Any tracking that a third-party performs is subject to their own privacy notice. Our third-party service providers may provide us information that tells us how our marketing ads, often placed on third-party websites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you, we would treat it as Personal Information.

  • Social Media Cookies: Social Media Cookies make social sharing easier for you, provide you with tools to connect with the Site, and help us better understand both the audience for the Site and the effectiveness of our social media outreach. These are third-party cookies. Your choices with respect to such cookies are determined by the social media platforms on which you have accounts.

Tracking Pixels (used by Bliss Point). A tracking pixel is a small snippet of code that allows us to collect information about advertising that we air.

1.5.2. Don’t Want Cookies?

Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example:

There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.

Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

1.6. Aggregated Statistics

Tinuiti collects statistics about the behavior of visitors to the Site. For instance, Tinuiti monitors the most popular blog posts or pages on the Site. Tinuiti may display this information publicly or provide it to others. However, Tinuiti does not disclose personally identifying information other than as described below.

2. USE OF YOUR INFORMATION

As mentioned, the information that Tinuiti collects and stores relating to you is used to communicate to you and to provide our services to you. Tinuiti takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of Personal Information.

We use your information for business and commercial purposes, including to use or browse the Site, to offer our Services, to provide you with customer service, to prevent security and fraud, to provide marketing information about our Services, and to perform website and mobile application analytics.

We may use the information we collect about you in a variety of ways, including to:

2.1. To Provide Our Services

We process certain Personal Information when you access or use our Services, including the following:

2.1.1. Functionality of the Site

We may collect information from users of the Site to improve website functionality and provide a test environment for our data collection infrastructure. This also enables us to customize experiences and personalization when you are on the Site.

2.1.2. Webinars and Events

We may collect information to facilitate various webinars and events that we host on topics such as marketing technology and measurement, media, and digital content creation.

2.1.3. New Services

We may collect information to offer new digital performance marketing services.

2.1.4. Bliss Point Service Offering

Bliss Point may collect information to provide advertising Services to our clients. Specifically, Bliss Point embeds Tracking Pixels into our advertising that we place with content publishers. The Tracking Pixel allows us to collect information from the content publisher about the advertising and its viewers. Bliss Point then matches this information with: (i) information that we collect from our clients about the consumers who visit the clients’ websites and applications; and (ii) information that we collect from other sources mentioned above, such as geolocation data. By matching the Tracking Pixel data with the data collected from the clients and other sources, we are able to evaluate and improve the effectiveness of the advertising we purchase on behalf of our clients.

 

2.2. To Communicate with You

We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

  • communicate with you about our Services, accounts and programs;
  • respond to your customer service inquiries and requests for information;
  • post your comments or statements on the Site;
  • contact you about our Services by any of the methods that you have consented to at the time we collected your information;
  • communicate with you about our brands, events, or other promotional purposes; and
  • implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives.

2.3. For Improvement of The Site

We want to ensure that the Site is continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

  • maintain, improve, and analyze the Site or Services;
  • understand how users interact with the Site and Services; and
  • detect, prevent, or investigate suspicious activity or fraud.

2.4. To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

  • maintain appropriate records for internal administrative purposes; and
  • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

2.5. To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use the Site, and Services, we may use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

2.6. Evaluate Your Application for Employment

We may use your Personal Information to evaluate your application for employment or administer employment benefits.

2.7. With Your Consent

We may process certain Personal Information in order to fulfill any other business or commercial purposes at your direction or with your consent.

2.8. Log Data

In addition, we may use log data for various internal business purposes which include:

  • To monitor abuse and prevent illegal activities and fraud,
  • To troubleshoot Service functionality and fix bugs;
  • To track people’s preferences which allows us to create new services, features and content that may be more personalized for you and your interests;
  • To track behavior on an aggregated/anonymous level to track and understand trends related to our offerings and services.

If you are a new customer, Tinuiti will only contact you when you have provided consent and only by those means you provided consent.

3. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

Tinuiti does not share your Personal Information with others except as indicated within this policy or when we inform you and give you an opportunity to opt out of having your Personal Information shared.

3.1  Third Party Service Providers, Employees, Agents or Contractors

Except as otherwise described in this Privacy Notice, Tinuiti discloses potentially personally-identifying and personally-identifying information only to those of our employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Tinuiti’s behalf or to provide services available through the Site, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Site, you consent to the transfer of such information to them. Tinuiti will not rent or sell potentially personally identifying and personally identifying information to anyone without advance notice. We do share information as described above with our website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to only use this information for the purpose in which Tinuiti shared it with them.

3.2 Third-party Disclosure for Joint Marketing Events & Digital Assets

For users in the United States, we sometimes participate in joint marketing events with third parties. On the registration page, it is clear who the other joint marketing party is. If you opt-into a joint marketing event or digital asset in the United States, we may provide your registration information to these third parties and partners for use in marketing and in designing or providing their own services, to send you information about their products and to notify you if you win a contest. You may opt out of us providing such information by opting out of our email newsletter and/or not registering for joint marketing events. You should contact the other third party directly who may already be sending you messages in order to request that these communications stop, and to review their privacy policies.

However, anonymized visitor information may be provided to other parties for marketing, advertising, or other uses.

3.3 Third Party Advertising

We share information about your use of the Site and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

We may participate in Facebook’s Custom Audience or LinkedIn’s Audience programs, which enable us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn respectively. We provide Personal Information such as your email address and phone number to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of participation in this program by contacting us as noted below. You may also opt out of receiving these ads from the social media network directly by visiting the following:

3.4 Who Bliss Point Shares Information With

Bliss Point shares Personal Information with our clients; Bliss Point also discloses data collected via tracking pixels with third parties in order to connect advertising with visits to our clients’ websites. Bliss Point does not disclose information that it collects from users of this Site. Bliss Point does not serve targeted ads using this data.

3.5 To Comply With Legal Process Or To Protect Tinuiti

Other than to its employees, contractors and affiliated organizations, as described above, Tinuiti discloses potentially personally-identifying and personally-identifying information in response to a subpoena, court order or other governmental request, or when Tinuiti believes in good faith that disclosure is reasonably necessary to protect the property or rights of Tinuiti, third parties or the public at large.

3.6 Business Transfers

If Tinuiti, or substantially all of its assets, were acquired, or in the unlikely event that Tinuiti goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Tinuiti may continue to use your Personal Information as set forth in this policy.

4. INTERNATIONAL TRANSFER OF DATA

Tinuiti operates the Site in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing Tinuiti with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as the European Union. Tinuiti service providers use appropriate safeguards to transfer your personal data to the United States.

  • Tinuiti may transfer data that we collect from you to locations outside of headquarters for processing and storing. In addition, it may be processed by staff operating outside the office area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Tinuiti will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Notice.
  • Data that is provided to Tinuiti is stored on our secure servers. Details relating to any transactions entered into via the Site will be encrypted to ensure its safety.
  • The transmission of information via the internet is not completely secure and therefore Tinuiti cannot guarantee the security of data sent to Tinuiti electronically and the transmission of such data is entirely at your own risk. Where Tinuiti has given you (or where you have chosen) a password so that you can access certain areas of the Site, you are responsible for keeping this password confidential.

5. THIRD PARTY LINKS

Tinuiti may have links on the Site to other websites that Tinuiti does not operate. If you click on a third-party link, you will be taken directly to that website, which is governed by its own privacy notice. Tinuiti strongly encourages you to read that privacy notice. Tinuiti does not control that website and assumes no responsibility for the content, policies or its practices.

6. CHOICES AND INDIVIDUAL RIGHTS

Tinuiti aims to take reasonable steps for you to correct, amend, delete or limit the use of your Personal Information. If you are a customer of one of our clients that works with Tinuiti and would no longer like to be contacted by them, please send your request to the client that you interact with directly. If our client requests Tinuiti to remove or amend that data, we will respond to that request within thirty (30) days.

Tinuiti outlines your choices below:

6.1. Email

As described above, if you do not wish to receive promotional emails from Tinuiti or for us to share your information with a joint partner in co-branded marketing events, you may opt out at any time. If you opt out of a promotional email, Tinuiti may still send you transactional and administrative emails about this privacy notice or about the Services for which you have contracted with us.

6.2. Cookies

Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.

6.3. Advertising

You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings.

6.4. Your rights under certain circumstances

To initiate any of these actions please contact us at [email protected].

  • To access and receive a copy of the Personal Information we hold about you.
  • To rectify any Personal Information held about you that is inaccurate
  • To request the deletion of Personal Information held about you
  • You have the right to data portability for the information you have provided to us. You can request to obtain a copy of this information in a commonly used electronic format so that you can manage and move it. We will need to verify your identity before being able to respond to such requests.
  • Please note that in some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

7. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

This section of the Privacy Notice applies solely to visitors, users, and others who reside or are located in the European Economic Area (“EEA”). We adopted this section to comply with European privacy laws, including the GDPR. Any terms defined in the GDPR have the same meaning when used in this Section. In most instances, Tinuiti is the data processor for processing Personal Information for our clients.

Tinuiti relies on the following lawful grounds to collect and process any personal data you may have provided:

  • Legitimate Business Interests: To notify you about any changes or improvements to Tinuiti services that may affect our service. If you are an existing customer, Tinuiti may contact you with information about our Services like those which were the subject of a previous transaction with you.
  • Performance of Contract: To meet Tinuiti’s contractual commitments to our clients and in performance of contractual obligations to our clients.
  • User Consent: If you are a user of the Site and have supplied your email address and provided consent, Tinuiti may occasionally send you email to tell you about industry news and information, solicit your feedback, or keep you up to date with what’s going on with Tinuiti and our services. We primarily use our email newsletter or email you updates on our blog to communicate this type of information.

We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Tinuiti relied on your consent to process your Personal Information.

7.1. Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

  • Processing of your Personal Information that you provide to us when you interact with our Services, such commenting in our community blog, watching our videos or making a purchase, is necessary to respond to or implement your request prior to entering into a contract with us.
  • When you apply for employment through the Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through the Site.
  • We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.
  • We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
  • Our use of data relating to your use of the Site and/or the Services, described above, is necessary for our legitimate interests in understanding how the Site and the Services are being used by you, to improve your experience on it and our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through the Site and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

7.2. Retention of Personal Information

Tinuiti will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

7.3. Automated Decision Making

Automated decision making refers to a decision that is taken solely on the basis of automated processing of your Personal Information. Bliss Point Media may use automated decision making for a variety of reasons, including optimizing the effectiveness of our clients’ advertising campaigns.

7.4. Exercising Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

7.5. Right to Lodge a Complaint

For European Union residents, if you feel that Tinuiti’s processing of your personal data infringes on data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you habitually reside, your place of work or the location of the alleged infringement. If you are located outside of the European Union, you may have rights under privacy laws in the jurisdiction where you live.

8. YOUR CALIFORNIA PRIVACY RIGHTS

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

8.1. Right to Access and Information Regarding Personal Information

You have the right to request, no more than twice in a 12-month period, that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of information we have collected about you;
  • The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
  • The categories of Personal Information about you that we disclosed for a business purpose.

We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within (forty-five) 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you through your account, if you maintain an account with us, or electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance. If we receive a Right to Know request regarding information that we process on behalf of our client, we will also recommend that the California resident submit a Right to Know request directly with the client, and will provide contact information for that client where feasible.

8.2. Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected from you. If we are able to verify your identity or the identity of your authorized agent, we will respond to your request by deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information.

We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information. We will specify the manner in which we delete your Personal Information. If a California resident submits a request to delete Personal Information to one of our clients and the client instructs us to delete the California resident’s Personal Information, we will delete the information as required by the CCPA. If we receive a Right to Deletion request regarding information that we process on behalf of our client, we will also recommend that the California resident submit a Right to Deletion request directly with the client, and will provide contact information for that client where feasible.

8.3. Right to Opt Out

You have the right to opt out of the disclosure of Personal Information about you for monetary or other valuable consideration. To Opt-Out, click Do Not Sell My Personal Information.

8.4. Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the foregoing rights, including by:

  • Denying you our Services;
  • Charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of our Services; or
  • Suggesting that you will receive different price or rate for our Services or at a different level or quality of our Services.

However, we may charge different prices or rates, or provide a different level or quality of our Services, if that difference is reasonably related to the value provided to us by your Personal Information.

8.5. Personal Information We Collect About California Consumers

We describe the Personal Information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled, “Personal Information Collected” above. The information we collect includes the following:

Category of Personal Information Collected Collected (Yes/No) Sources of Personal Information Collected
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above. Yes You

Automatically

Third Parties

The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. Yes You

Automatically

Third Parties

Characteristics of protected classifications under California or federal law list any of these that you collect: race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. Yes You

Automatically

Third Parties

Commercial information, including information about orders or purchases of any of our Services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. Yes You

Automatically

Third Parties

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, mobile apps, advertisements that we display on the Site or mobile apps or on third party websites and apps, or Tinuiti pages or accounts on any third-party social media platforms. Yes You

Automatically

Third Parties

Geolocation data. Yes Automatically
Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above. No N/A
Professional or employment-related information Yes Automatically
Education information No N/A
Inferences drawn from (1) the information we collect when you visit the Site, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on the Site and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. Yes You

Automatically

Third Parties

Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number. No You

We collect this Personal Information from sources that include our clients and other sources referenced in the “Personal Information Collected” section above.

8.6. Disclosure of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes

Under the CCPA, sharing of Personal Information that is necessary to provide you with personalized ads and with some of our partners may be considered a “sale,” even if no money is exchanged. In that respect, we may disclose email addresses and contact information to other businesses and third parties that include our joint marketing partners when we host webinars and events with them within the twelve (12) months preceding the effective date of this Privacy Notice. In addition, Bliss Point may purchase, use and share for commercial purposes consumer data across consumer devices to deliver advertising via our proprietary graph-matching technology. As is common practice among businesses that operate websites, we may also disclose certain online identifiers, information about the use of the Site and inferences drawn about you to our social media, advertising and analytics partners.

We have disclosed Personal Information in all or substantially all of the categories identified in this section for various business purposes.

Category Categories of Third Parties We Share With Whether We “Sold” This Category of Personal Information in the Last 12 Months
1. Identifiers such as name, address, email address, phone number. ·  Advertising partners

·  Analytics providers

·  Media platforms

·  Clients (and their service providers)

·  Social media networks

·  Consumer data resellers

·  Distribution partners

Yes
2. The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. N/A No
3. Characteristics of protected classifications under California or federal law ·  Advertising partners

·  Analytics providers

·  Media platforms

·  Clients (and their service providers)

·  Social media networks

·  Consumer data resellers

·  Distribution partners

Yes
4. Commercial information, including information about orders or purchases of any of our Services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. N/A No
5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, mobile apps, advertisements that we display on the Site or mobile apps or on third party websites and apps, or Response Media pages or accounts on any third-party social media platforms. ·  Advertising partners

·  Analytics providers

·  Media platforms

·  Clients (and their service providers)

·  Social media networks

·  Consumer data resellers

·  Distribution partners

Yes
6. Geolocation data. ·  Advertising partners

·  Analytics providers

·  Media platforms

·  Clients (and their service providers)

·  Social media networks

·  Consumer data resellers

·  Distribution partners

Yes
7. Audio information from calls placed with customer service that may be reported, and electronic information in the form of Internet or other electronic network activity information described above. N/A No
8. Professional or employment-related information N/A No
9. Education information N/A No
10. Inferences drawn from (1) the information we collect when you visit the Site, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on the Site and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. ·  Advertising partners

·  Analytics providers

·  Media platforms

·  Clients (and their service providers)

·  Social media networks

·  Consumer data resellers

·  Distribution partners

Yes

For more information about the categories of Personal Information we have disclosed, the categories of entities with which we have disclosed this information and the purposes for which we have disclosed the information, please see “Use of Your Information” above and “Where and How We Share and Disclose Your Information”.

For information regarding the purposes for which we collect and use the Personal Information we collect, please see “Use of Your Information” and “Where and How We Share and Disclose Your Information” sections above.

8.7. Requests to Exercise Your Rights

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within ten (10) business days describing our verification process. We will respond to your request within forty-five (45) calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

We will maintain records of requests made pursuant to the CCPA for a period of at least 24 months.

8.8. Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at [email protected] or by writing us at the address below.

9. SECURITY

Tinuiti cares about the security of your Personal Information. Although we cannot guarantee 100% security, we use reasonably appropriate security measures to protect your Personal Information against unauthorized use, access, modification, destruction or disclosure. We require our third-party service providers to use similar safeguards to those we use.

10. SENSITIVE DATA

Tinuiti requests that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send Tinuiti this information, then you are consenting to its processing in accordance with this privacy notice. To avoid processing of sensitive data, do not submit it.

11. OUR POLICY ON CHILDREN’S INFORMATION

The Site is not directed to children under 16. If we learn that we have received Personal Information from a child who is under 16, we will delete the data. If you learn that your minor child has provided Tinuiti with Personal Information without your consent, please contact us at [email protected].

12. PRIVACY NOTICE CHANGES

Although most changes are likely to be minor, Tinuiti may change its Privacy Notice from time to time, and in Tinuiti’s sole discretion. We will indicate at the top of the page the modified notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

13. ACCESSIBILITY

Any person with a disability that prevents or restricts them from accessing this Privacy Policy through our website may request a copy of the Privacy Policy in an alternative format by contacting us at [email protected] or 833-846-8484.

14. CONTACT US

Tinuiti welcomes any queries, comments or requests you may have regarding this notice.

Tinuiti, Inc.
Attn: Marketing Department
121 S 13th Street, 3rd Floor
Philadelphia, PA 19107

Email: [email protected]

Phone: 833-846-8484