Last modified: March 21, 2023
Numerator provides products and services to our clients (such as agencies, brands, manufacturers and retailers) to help them better understand consumer behavior and the markets in which they do business.
Please note that:
- This Policy does not cover our clients’ use of your personal information outside of the products and services we may provide them. We are not responsible for the privacy practices of our clients. Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by third parties. Any such participation will be subject to the relevant third party’s terms and conditions.
PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT
We may collect your information in several ways, including the following:
- Information You Provide Us Directly. We collect personally identifiable information which you choose to provide us directly.
- Information We Receive from Our Clients. We may collect information from our clients who provide your information to us so that you (for the benefit of the client) are able to login to our sites and/or services.
- Information We May Receive from Other Parties. We may combine the information we receive from you with information we receive from other sources.
We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so under applicable law. The chart below summarizes when we collect personal information, the types of personal information we collect and how we use the personal information.
|When We Collect Personal Information||The Types of Personal Information We Collect||How We Use Personal Information||The Legal Basis for Using Personal Information|
|Personal information we collect by cookies or similar technologies when you visit our website.||We may collect data related to your use of our site including where you came from, login details, pages you looked at, duration of your visit, geographic location, and/or the links you click. Technical information collected may include your browser type and operating system, device information, and your Internet Protocol (“IP”) address.||We may use this information to tailor our website for you, that is to show you recommendations, marketing, or content based on your profile and interests. This data also allows our website to function properly, that is to ensure the proper display of content, create and remember your account login details, improve our site and keep our site secure and safe and to protect against fraud. This data may also be used to show online ads and content on social media platforms or other sites. You can opt out of targeted advertising by using the function available on our site (where applicable), or in your browser settings. For opting out of targeted advertising on social media platforms, please visit the relevant social media platform to explore the options they may provide.||Our legal basis to use this information includes our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our sites.|
|Personal information we collect and use when you subscribe to receiving our marketing communications.||We collect first and last name, organization name, gender, email address, mailing address, username and password, preferences, and other information you have chosen to share with us about yourself.||We may use this information to send you marketing communications (where you have asked us to) which may be tailored to you based on your preferences and the personal data we know about you.||Our legal basis for using this information includes (1) our legitimate interests which include to improve our sites and services and better engage with you (2) your consent (if required by law) to receive marketing communications from us.|
|Personal information we collect and use when you contact our support team||We may collect first and last name, email address, phone number, date of birth, information about your activities and interests, and other information you have shared with us about yourself in relation to your inquiry.||We use this information to communicate with you about your use of our services and may use it to verify your identity for compliance reasons
|Our lawful basis to use this information includes (1) performance of contract to provide you with our service (2) our legitimate interests which include to improve our services, to better engage with you and to secure our sites.|
|Personal Information we collect and use if you apply for employment with Numerator||We collect your education, employment history, qualifications, and the contact information of a former colleague.
If you are a resident of California, see our California Job Applicant Privacy Notice here for more information about our privacy practices relevant to applicant data.
|This information is used for job reference purposes only and is not used for any other purpose. This information is collected from the individual directly.||Our legal basis to use this information is your consent.|
HOW WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES
We may share the categories of personal information we obtain about you (as described above) with the categories of third parties listed in this section.
- We share information with third parties for advertising purposes as described below under “Cookies and Similar Technologies”.
- We may share your personal information with third party service providers or data processors that help provide analytics regarding the use of our products and services, manage our business or deliver services, for example, IT service providers who help manage our IT and back office systems or administer our sites and services. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
- We may share information with government organizations and agencies, law enforcement and regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
- We may share in aggregate, statistical form, non-personal information regarding the visitors to our sites with our partners, affiliates or advertisers.
- If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.
In addition to the above, we may share personal information about you with others to the extent you consent to such sharing.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
International data transfers
COOKIES AND SIMILAR TECHNOLOGIES
When you visit our website or click on a banner advertisement, we and our partners, affiliates, or analytics or service providers may send one or more cookies or similar technologies to your computer or other device to collect information that helps us improve the quality of site and service and the online experience of our visitors and users. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained below:
- Cookies and other data collection technologies: We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage:
- Required cookies: These cookies are necessary to enable the basic features of our site to function, such as allowing images to load or allowing you to select your cookie preferences.
- Functional cookies: These cookies allow us to analyze your use of our site to evaluate and improve our performance. They may also be used to provide a better customer experience on our site. For example, remembering your log-in details or providing us information about how our site is used.
- Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.
How we use personal information to keep you up to date with our services
We may use personal information to let you know about our services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activities with you.
We also work with carefully selected third parties, such as promotional partners and others with whom we have marketing or other relationships. At all times, in accordance with your marketing preferences, these third parties may contact you by email, SMS/text, social media or through other communications channels to tell you about products and services that they believe would be of interest to you.
At any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communicate with you. You can ask us to stop direct marketing at any time by following the unsubscribe link you will find on all the email marketing messages we send you. Alternatively you can contact us email@example.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email).
You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser. We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences in your account with us. Further, if (in accordance with your marketing preferences) you receive marketing from the third parties referred to above, we recommend you review any relevant third party’s privacy notice for how they use your personal information.
Be aware that if you unsubscribe from our marketing communications we may be unable to notify you of services or offer to meet your needs. If you unsubscribe from marketing communications from us, you may still receive operational and service messages from us.
Please note that information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. We are unable to control any use of such information by these third parties.
COLLECTION OF INFORMATION FROM CHILDREN
None of our products or services are intended for use or purchase by children. Accordingly, we do not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us at firstname.lastname@example.org
INFORMATION FROM THIRD PARTIES
We may receive information about you from third party companies that specialize in collecting publicly available information. This may include estimated demographic information and information from public registers, such as the electoral register. We may link information about you that we collect from these third parties with other information that we collect about you.
YOUR RIGHTS AND CHOICES
Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account and contacting us through our support channels or contacting us at email@example.com. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, verify your identity, or may need to retain your personal information in order to continue providing a service. You can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. You also may update certain of your account details and settings by logging into your account on the Services.
If you are a Colorado, Connecticut, Utah, or Virginia resident, subject to applicable law, you may have the right to: (1) request access to, or correction or deletion of, your personal information; or (2) opt out of the processing of your personal information for purposes of targeted advertising, or the sale of your personal information. You can exercise your rights by emailing us at firstname.lastname@example.org or, for requests to opt out of sale or targeted advertising, by visiting our opt-out request form here To the extent permitted by applicable law, you may appeal our decision with respect to a request you have submitted by emailing us at email@example.com.
LEGAL RIGHTS AVAILABLE TO EU/UK DATA SUBJECTS
Subject to applicable law, you have the right to request access to the personal information we maintain about you, rectification of your personal information if it is inaccurate or outdated, or erasure of your personal information in certain circumstances specified by applicable law. You may also request the restriction of the processing of your personal information or object to that processing on grounds relating to your particular situation. In addition, and subject to applicable law, you have the right to receive a copy of your personal information in a structured, commonly used, machine readable format, and, in some cases, may have the right to have that personal information transmitted to another organization.
You can exercise your rights by sending a request to firstname.lastname@example.org or to the mailing address referenced in the Contact Us section. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
On our service platform (e.g., Numerator Insights), Numerator collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer or employee of one of our clients and would no longer like to be contacted by one of our clients that uses our service, please contact the client that you interact with directly.
Numerator acknowledges that you have the right to access your personal information. Numerator has no direct relationship with the individuals whose personal data it processes on our service platform. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Numerator’s client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
The primary point of contact for all issues arising from this Policy is our Data Protection Officer. Our Data Protection Officer can be contacted in the following ways:
Email: email@example.com Attn: Numerator Privacy Market Track, LLC 24 E. Washington St., Suite 1200
Chicago, IL 60602 Phone: +1.312.529.5102
If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority. For the EU, your local authority can be found here.
FOR CALIFORNIA CONSUMERS – CALIFORNIA CONSUMER PRIVACY STATEMENT
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
Notice of Collection and Use of Personal Information
- Identifiers: including real name, postal address, unique personal identifier (such as cookies, mobile ad identifiers and similar technology), internet protocol address, email address, account name, and other similar identifiers if you provide them
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
· Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
· Providing advertising and marketing services;
· Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
· Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;
· Helping to ensure security and integrity;
· Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
· Debugging to identify and repair errors;
· Undertaking internal research for technological development and demonstration; and
· Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.
We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
During the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement, we may have obtained personal information about you from the following categories of sources:
· Directly from you, such as when you contact us
· Your devices, such as when you use our Services
Sale or Sharing of Personal Information
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services: Identifiers.
You have the right to opt out of these disclosures of your information, as detailed below.
We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
Disclosure of Personal Information
During the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information||Categories of Third Parties|
|Identifiers||· Our affiliates and subsidiaries
· Vendors who provide services on our behalf
· Our joint marketing and business partners
· Online advertising services
· Social networks
|Online Activity||· Our affiliates and subsidiaries
· Vendors who provide services on our behalf
· Our joint marketing and business partners
· Online advertising services
|Geolocation Data||· Our affiliates and subsidiaries
· Vendors who provide services on our behalf
· Our joint marketing and business partners
· Online advertising services
In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you during the past 12 months.
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we will verify your identity by requiring you to sign in to your account and/or answer security questions related to your account. If you do not have an account with us, or an email address on file with us (such as if you signed up to receive our marketing emails), then there may not be a reasonable method by which we can verify your identity to the level of certainty required by the CCPA. This is because historically we have not linked device identifiers or advertising IDs to named actual persons. Accordingly, if you do not have an account with us, or an email address on file, and you request access to, correction of or deletion of your personal information, we will not be able to process your request at this time.