Adventive Privacy Policy

This Privacy Policy is effective as of January 1, 2020.

We have updated our May 25, 2018 privacy policy to address new products and services, clarify the collection and use and protection of the personal data that we receive, and to address the new California Consumer Privacy Act (CCPA).

This Adventive Privacy Policy (“Policy”) outlines the information that Adventive, Inc. (“Adventive”, “we”, “us” or “our”) gathers, how we use that information, and the options you have to access, correct or delete such information.

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01. POLICY APPLICATION.

This Policy applies to Adventive’s collection, use, and disclosure of the information of the following categories of data subjects:

• Attendees: Those who provide their information to Adventive when they attend or register to attend Adventive-sponsored events, webinars, demonstrations or other events at which Adventive participates.

• Website Visitors: Those who visit our Websites and who may opt to provide an email address, name or other information to receive communications from Adventive. For the purpose of this Policy, “Websites” shall refer collectively to www.adventive.com as well as any other websites Adventive owns and that link to this Policy. For clarity, “Websites” does not include any sites owned or operated by our Subscribers, including where we serve ad units.

• Subscribers: Those who register on their own or on behalf of an entity or organization to use any of Adventive Services. For the purposes of this Policy, “Services” shall refer to all of the cloud-based solutions offered, marketed or sold by Adventive or its authorized partners.
  

• Viewers: Those who access or use our Subscribers’ domains or who otherwise view an advertisement on our Subscribers’ domains or domains which serve advertisements delivered by Adventive.

Adventive’s Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen.  Adventive does not knowingly collect personally identifiable information from any person under the age of eighteen.

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02. INFORMATION WE COLLECT.

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Attendees

• We may ask for and collect personal information such as your name, address, phone number and email address when you register for or attend an Adventive-sponsored event, webinar, demonstration or other events at which Adventive participates.

Website Visitors

• Name, email address, and other contact information. We ask for and, at your option, collect personal information from you when you submit web forms, chat forms, or for email communications for which you sign up for and agree to receive on our Websites. We may also ask for you to submit such personal information if you choose to participate in any surveys, promotions, contests, request customer support, or otherwise communicate with us. We will send such communications in accordance with applicable law.
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• Log files. When visiting our Websites, we gather certain information and store it in log files. This information may include, but is not limited to, Internet Protocol (IP) addresses, system configuration information, referring URLs, locale and language settings.
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• Cookies and Other Tracking Technologies.  We use cookies and other tracking technologies for a variety of purposes, such as assisting in marketing efforts and providing information on how you interact with our Websites.  As a Website Visitor, you can control how websites use cookies by configuring your browser’s privacy and security controls, further, if you wish not to have this information used for the purpose of serving targeted, internet-based ads, you may opt-out by clicking here to access tools from the Network Advertising Initiative, or if you are located in the European Union, United Kingdom, or Switzerland by clicking here to access tools from Your Online Choices. For comprehensive information regarding the cookies that Adventive uses and your privacy choices, please see our Cookie Policy.
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• Forums and Knowledge Bases.  The Websites may offer publicly accessible community forums, blogs, and knowledge bases which may provide comment or discussion sections.  Posting in any of these comment or discussion sections may lead to your information being read, collected, and used by others who access it. If you wish remove your personal information from any of the publicly accessible community forums, blogs or knowledge bases, please see Section 8, below.

Subscribers

• Subscriber Account Information.  When you register for an account to utilize one or more of our Services, we collect certain personal information about you, which includes your full name, email address, optional title and optional phone number. By voluntarily submitting this Subscriber Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
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• Billing & Payment Information. When you register for an account to utilize one or more of our Services, we collect personal information about the primary account contact, including full name, email address, title, business address, business phone number, website URL, billing contact information including phone number, address, VAT ID (if applicable), and billing statement email addresses.  When registering for one or more of Adventive’s paid services, you are required to provide billing and payment information and by providing such information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

Viewers

• Adventive processes Viewers’ information on behalf of our Subscribers when Viewers view an advertisement on our Subscribers’ domains or domains which service advertisements delivery by Adventive. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, referring URLs, browser locale and language settings.

03. HOW WE USE INFORMATION WE COLLECT.

Adventive only processes personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized. For all categories of data described in Section 2 above, we may use the information (including personal information, to the extent applicable) to:

• Provide, operate, maintain, improve and promote the Websites and Services for all users of the Website’s and Services;
• Send transactional messages, including responses to your comments, questions, support requests, technical notices, security notices, and other administrative messages;
• Process and complete transactions, and send related information including invoices;
• Send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, newsletters, offers, promotions, contests and news or information about us;
• Process and deliver contest or sweepstakes entries and rewards;
• Monitor and analyze trends, usage, and activities in connection with the Websites and Services for marketing and advertising purposes;
• Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
• Process for other purposes for which we obtain your consent.

Information from Third Party Services. We may combine information we collect as described above with personal information obtained from third parties.  For example, we may combine information entered on the Adventive sales form with information received from a third-party sales integration vendor to enhance our ability to market our services to Customers or potential customers.

04. DATA AGGREGATION.

Adventive aggregates data we acquire from our Website Visitors, Subscribers and their Viewers, including Log Data described above. Non-personally identifiable, aggregated data may be shared with third parties.

05. NOTICE TO EU RESIDENTS.

Adventive is a data controller for the Personal Data collected from all categories of data subjects listed above expect for the Personal Data of Viewers.  Adventive processes the Personal data of Viewers on behalf of its Subscribers.

If you are an individual from the European Economic Area (“EEA”), the United Kingdom or Switzerland, please note that Adventive’s legal basis for collecting and utilizing personally identifiable information will depend on the personal information collected and the specific context in which we collect it. We will normally collect personal information from you when: (a) you have provided your consent to do so, (b) we need your personal information perform a contract with you (e.g. deliver Adventive Services you have requested), (c) where the collection and processing of the personal information is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, Adventive will no be able to provide the requested service(s) to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.  Where we rely on your consent to process your personal information, you have the right to withdraw or decline your consent at any time. The withdrawal of consent shall not affect the lawfulness of the processing based on consent prior to its withdrawal. Where we rely on our legitimate interests to process your personal data, you have the right to object.

Should you have additional questions or require further clarification concerning the legal basis for which we collect and use your personal information, please contact us at privacy@adventive.com.

06. INFORMATION SHARING.

Adventive works with other companies who help us to run our business (“Service Providers”).  These companies provide services to help us deliver our customer support, payment processing, manage and contact existing customers as well as sales leads, provide marketing support and otherwise operate and improve our services.  These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations, including obligations under the EU-US and Swiss-US Privacy Shield frameworks described in Section 7, below.

Specifically, we do not permit our Service Providers to sell any personal information we share with them or to use any personal information we share with them for their own marketing purposes or for any purpose other than in connection with the services they provide to us in the course of the operation of our business.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

• With our resellers and other sales partners who may help us distribute Adventive Services to Subscribers;
• In the event of a merger, sale, change in control, or reorganization of all or part of our business;
• When we are compelled to disclose personal information to respond to subpoenas, court orders, legal process, or to establish or exercise or legal rights or defend against legal claims;
• Where we have a good-faith belief that sharing information is necessary in the investigation of, or to prevent illegal activities, fraud, potential threats to the physical safety of any person, the protection of minors, violations of our Master Services Agreement, or otherwise as required by law.

Notice to California Residents: Adventive does not sell, rent, or share personal information with third parties as defined under the California Consumer Privacy Act of 2018 (California Civil Code Sec 1798.100 et seq.), nor do we sell, rent or share personal information for their direct marketing purposes as defined under California Civil Code Sec 1798.83.

07. INTERNATIONAL INFORMATION TRANSFERS.

Adventive is a U.S.-based, global company.  Information that we collect and obtain from you is primarily stored in the United States.  To facilitate our global operations, we may transfer and access such information from around the world for the purposes described in this Policy.

Whenever Adventive shares personal information originating in the EEA, the United Kingdom, or Switzerland with an entity outside the EEA, the United Kingdom, or Switzerland we will do so on the basis of the EU standard contractual clauses (adjusted to address transfers from the United Kingdom) or the Privacy Shield Frameworks detailed in this section, below.

If you are accessing or using our Websites or Services, or otherwise providing information to us, you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we may operate.

Privacy Shield.  Adventive is certified with, and complies with both the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the EEA, the United Kingdom and Switzerland to the United States, respectively (“Privacy Shields”).

We commit to the periodic review and verification of the accuracy of our policies and our compliance with the Privacy Shields.  If there is any conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  For more information on the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks, please visit the U.S. Department of Commerce’s Privacy Shield website at: https://www.privacyshield.gov/welcome.

If you believe that we maintain copies of your personal information within the scope of the Privacy Shields, you may direct any inquires to privacy@adventive.com or via mail to:

Adventive, Inc.
Attn: Data Protection Officer
140 Allens Creek Rd, STE 220
Rochester, NY 14618
United States

We will respond within 30 days of the receipt of your inquiry and successful verification of your identity.

08. DATA SUBJECT RIGHTS AND CHOICES.

• Attendees, Website Visitors, Subscribers: You have the right to access, correct, update, export, or delete your personal information.  You may email at privacy@adventive.com, and we will respond within 45 days.  Subscribers can also access, correct, export or update their Account Information by editing their profile or organization settings in Adventive.
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• Viewers: Adventive has no direct relationship with Viewers, unless Adventive is the owner of the domain on which an advertisement was served, we have no control over a domain’s content.  Accordingly, we rely upon our Subscribers to comply with the underlying legal requirements for access requests.  Our Subscribers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their website users.  

09. COMMUNICATION PREFERENCES.

Adventive will send you commercial communications based on the communication preferences in your account settings. Adventive also will send you service-related communications. You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the bottom of such emails.

10. DATA SECURITY, INTEGRITY AND ACCESS.

Adventive takes all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, modification or destruction. We’ve implemented appropriate physical, technical and administrative measures to safeguard and secure your information.  If you have any questions about the security of your personal information or our security practices, please contact us at privacy@adventive.com.

11. NOTIFICATION OF CHANGES

Adventive reserves the right, at any time, to add to, change, update, or modify this Privacy Policy.  If, in our reasonable discretion, the changes are material, we will post a notice on our website or send you an email.  The modified Privacy Policy will be posted on this website along with the effective date.  You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. BUSINESS TRANSACTIONS.

Adventive may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all or part of our business.

13. ENGLISH LANGUAGE CONTROLS.

Non-English translations of this Policy may be provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

14. DISPUTE RESOLUTION.

As part of our commitment to the Privacy Shield Principles, if you are a resident of the European Union or Switzerland and you have a privacy or data use concern, please contact Adventive directly at privacy@adventive.com and Adventive will use its best efforts to address your concern within 45 days of receipt of your complaint. For an unresolved privacy or data use concern that Adventive has not addressed satisfactorily, please contact our U.S. based third party resolution provider (free of charge) at https://www.bbb.org/EU-privacy-shield/for-eu-consumers/.

For any Privacy Shield disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has investigation and enforcement authority over Adventive’s compliance with the Privacy Shield Framework.

15. CONTACT INFORMATION.

If you have any comments, concerns or questions regarding this Privacy Policy or our privacy practices in general, please send an email to privacy@adventive.com, or send mail to:

Adventive, Inc.
Attn: Privacy Department
140 Allens Creek Rd STE 220
Rochester, NY 14618

Your right to file a complaint with a data supervisory authority about our privacy practices remains unaffected.

Under California Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@adventive.com.