Privacy Policy

UNTU, LLC (“we”, “us”, or “our”) is committed to respecting your privacy rights. Our targeted digital advertising offerings and ad targeting technology delivers targeted digital advertisements online and on mobile devices for B2B and B2C advertisers (our “Service”).

We created this Privacy Policy (“Privacy Policy”) in order to demonstrate our commitment to you (“you” or “your”), our Customers, Visitors and Audience Members (all defined below), regarding your privacy with respect to information that we collect about you or that you submit to Us via the Service or through our internet website located at UNTU.us (the “Website”).

UNTU, LLC, owner and operator of the Website and the Service, is a limited liability company formed under the laws of the State of Delaware, United States.

This Privacy Policy applies to our “Customers,” who are B2B and B2C advertisers that use our Service and individuals acting on behalf of such Customers; to “Visitors,” who are visitors to our Website and may include Customers; and to “Audience Members,” who are actual or potential individuals about whom we receive Personal Information from our Customers when We are acting as a provider of our Service to our Customers.

This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein.

NAI MEMBERSHIP & COMPLIANCE

UNTU, LLC is a member of — and adheres to the Code(s) of Conduct of — the Network Advertising Initiative (NAI), the leading self-regulatory association dedicated to responsible data collection and its use for digital advertising. The NAI is an organization for third-party online advertising technology companies, including networks, exchanges, DMPs, SSPs, RTB platforms, analytics companies, and service providers.

The NAI’s role is to help promote consumer privacy and trust by creating and enforcing high standards for responsible data collection and use practices online and in mobile environments among its members. You can find a description of policies listed here: NAI Self-Regulatory Codes of Conduct. By abiding by the NAI’s Codes of Conduct, we demonstrate commitment to consumer privacy and digital advertising best practices.

You can find the NAI opt-out tool here, which allows you to opt-out of Interest Based Advertising.

PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means any information or set of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal Information” does not include information that is not associated with an identified or identifiable individual or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person or household), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly. For purposes of this Privacy Policy, Personal Information encompasses both “personal data” under the General Data Protection Regulation (“GDPR”) and “personal Information” under the California Consumer Privacy Act of 2018 (“CCPA”).

NOTICE

Where we collect or receive Personal Information about you directly from you, we will explain the purposes for which we collect and use such Personal Information, the types of third parties to which we disclose that information, and the choices and means, if any, we offer you for limiting the use and disclosure of Personal Information about you. This explanation will be provided as soon as practicable and, in any event, before we disclose your Personal Information or use such information for a purpose materially different than that for which it was originally collected or processed.

Where we collect or receive Personal Information about you from our Customers, which occurs when we are acting as a provider of Services to our Customers, we do so as a processor (under GDPR) and/or service provider (under CCPA) of Personal Information on behalf of our Customers. We will use such information in accordance with the notices provided by our Customers and in accordance with the choices you made with respect to such Personal Information, as communicated to us by our Customers.

Collection of Personal Information

Information You Voluntarily Provide Us: When you visit our Website or use our Service, we may collect certain types of information that you submit voluntarily. You will need a username and password from us in order to access the protected areas of the Website, including the Service. We require some limited information to create an account for you, including your user name, password, email address, mailing address and telephone number. In addition, if you are accessing the Website or our Service on behalf of a Customer, you may provide certain information, for example, the Customer’s name, email address, and password. We also collect certain information from you in order to process transactions on our Service, including credit card numbers and associated billing information. We refer to this information as “Billing Information.” Our legal basis for processing this information is your consent.

Information We Collect From Third Parties: We may also acquire information about Audience Members from third parties, including from our Customers and other trusted sources, including the following information:

• Name, Email Addresses, etc. This information may include name, email address, mailing address and telephone number, as well as demographic and voting data to supplement this information. Those third parties have privacy policies that may differ from this Privacy Policy. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties including their use of technologies to gather information about you.  Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our Service, and the legitimate interests of our Customers (“data controller” under GDPR and/or “business” under CCPA).

• Sensitive Data and Sensitive Health Data. Certain information that we collect from third parties may also be considered “Sensitive Data.”  Sensitive Data may include social security numbers and bank or credit card account information. Sensitive Data may also include information about your race or ethnicity, or personal health and medical information such as information on personal health conditions and treatment (“protected health information” or “PHI”), prescriptions for medications and laboratory results (“Sensitive Health Data”).

Please click on the following link for examples of the categories of Sensitive Health Data that we collect from third parties, including from our Customers and other trusted sources, and that we use for our Services, both “standard” or “off-the-shelf” audience segments and “custom” audience segments used for the same purposes: https://untu.us/audience-segments/

Please be aware that, unless appropriately de-identified, PHI collected by us may be protected under the Health Insurance Portability and Accountability Act of 1996, as amended.

• Device-Identified Information (“DII”). DII is technical information that is linked to the browser, device or group of devices you use, but is not intended to be used to directly identify a particular individual.  Examples of DII include your device’s Internet Protocol (IP) address, browser type, and operating system. Additionally, in the case of mobile devices, we or our service providers may collect your device’s type and unique advertising identifier (such as the Apple IDFA (or UDID in older Apple phone models) or Android Advertising ID / Google AdID), and any other unique identifier that may be assigned to your device, or a non-cookie unique identifier, so long as the identifier is not linked or intended to be linked to Personal Information when ultimately used for interest-based advertising.  This information may also include information reflecting your viewing behavior and other interactions with connected televisions (or “smart TVs”) and unique advertising identifiers associated with your smart TV. Nonetheless, please note that in certain contexts and jurisdictions such as under the CCPA and the GDPR, DII that we do not regard as Personal Information, such as IP addresses, may nevertheless be regarded as Personal Information.

• Geo-location data. This is non-precise information related to your geographical location derived from your device’s IP address (e.g. laptop, desktop or mobile etc.). This information does not reveal your precise geographic coordinates (i.e. GPS latitude and longitude). Examples include your zip code or the approximate geographic area provided by your Internet service provider (ISP) or location positioning information provided by the location services and GPS features of your mobile device or website when location services are enabled on your device.  This information helps us and our service providers to serve ads that are relevant to your general location (for example, showing ads in French if you are located in France).  We may also infer the geo-location of your device based on data collected through, for example, a WiFi identifier that the device is connected to.

• Offline Data for Audience Matching. As described in additional detail in “Audience Matching Services (on-boarding),” we may collect customer relationship data (such as email addresses or “hashed” versions of email addresses) from our Customers or from other third parties, in order to provide audience matching services as part of our Services, sometimes referred to as “on-boarding.”

Information We Automatically Collect via Our Website: Whether you are a Visitor visiting our Website or acting on behalf of a Customer visiting our Website, we automatically collect certain information that your browser sends when visiting websites in general. This information, often referred to as “Log File Information”, may include the URLs you visited; your IP address; date and time when visiting our Website and time spent on pages visited; and information about your browser and platform. In addition, when you use the protected areas of the Website, certain Log File Information about your use is automatically recorded and retained, such as account activity (e.g. number of log-ins), and data displayed or clicked on (e.g. user interface elements, links). This information may also include Cookies, web bugs, device information, and navigational data like Uniform Resource Locators (URLs), which we may use to gather information regarding the date and time of your visit, as well as your geo-location (from your IP address). “Cookies” are small pieces of information that a website sends to your browser; please see our Cookie Policy for information about our use of Cookies. Our legal bases for processing this information is both your consent and our legitimate interests, namely monitoring and improving our Website and Service.

Use of Information We Collect

We use the information we collect to respond to requests, resolve problems, maintain our Customers’ accounts and provide our Services to our Customers including to measure or understand the effectiveness of our Services, provide our Website to you, improve our offerings and to create new services, and market our products or services and those of our affiliates, partners and third parties to you.

We may also use the Personal Information that we collect to send you certain Service and administrative notices, which are not subject to opt out.

We use Billing Information that we collect only for purposes of authentication and to process transactions on the Service.

We may also use information collected above to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.

Interest-Based Advertising. Our Service helps our Customers deliver advertisements to people that are most likely to find them interesting by showing them advertisements that are relevant to the specific interests of the people receiving them. This is called “interest-based advertising.” We deliver many of these interest-based ads on websites and mobile applications which rely on advertising revenue to support the content they provide.

In doing so, we may utilize the segments referred to in “Information We Collect from Third Parties” (including Sensitive Health Data), as well as Personal Information and non-Personal Information derived from your browsing habits on the Internet, to target specific ads to individuals. Our Service uses that data to help our Customers provide ads and send advertisements to you that aim to be more relevant to you. This allows our Customers who use our Service to provide more effective advertising that reaches a more precise pool of prospective buyers.

 We may also serve ads to you based on inferences we have made regarding health conditions that may be of interest to you. We may make these inferences using models based on a sample set of other users’ health records, which we then compare with information in our databases to create datasets we can use to make certain predictions or inferences regarding characteristics that may apply to you, including the existence of certain medical conditions.

 You can control how you share your Personal Information with us, including electing to opt-out of interest-based advertising altogether. Please visit our opt-out page to opt-out.

Aggregated / Anonymous information. We may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service. Information that is in “aggregate / anonymous” form refers to non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly.

Cookies and Log File Information. We use Cookies, other identification technologies and Log File Information to provide personalized content and to administer and monitor usage of the Service and Website. We also use Cookies, other identification technologies and Log File Information to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Audience Matching Services (on-boarding). We use Personal Information we collect in order to provide audience matching services as part of our Services, sometimes referred to as “on-boarding.” Audience matching is a particular type of interest-based advertising where we share de-identified offline information (e.g. “hashed” versions of email addresses) with an ad partner or incorporating a pixel or mobile ad IDs from an ad partner into our own Services, and the ad partner “matches” common factors between our information and the ad partner’s information or other datasets to cookies, mobile ad IDs or other online identifiers. We use this information only as a processor for the purpose of providing Services to that particular Customer. We do not share this information with other Customers for purposes of providing our Services.

Cross-device Linking. We use Personal Information we collect in order to identify different devices and browsers that are likely to be associated with you so that ads can be targeted, limited and/or and sequenced across those devices, and so that our Services can be better measured and analyzed. For example, cross-device linking helps us not show you ads for the same topic or product or service that you were looking at on your phone but already acted upon via your tablet. Cross-device linking also improves our ability to match devices in order to receive and honor your opt-out choices across all devices. You may opt-out of cross-device interest-based targeting by employing the respective opt-out techniques we describe in “Your Choices and Opting-Out of Interest-Based Advertising and Analytics.”

CHOICE

(Disclosing Personal Information to Third Parties)

We will offer you the opportunity to choose whether your Personal Information is to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you.

General. We may disclose Personal Information: To third party vendors or service providers who help us provide the Service or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request; To third parties to whom you ask us to send your information; To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy; To a company that merges with us, acquires us, or purchases our assets, in which case such company may continue to process your information as set forth in this Privacy Policy; or If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Customer contracts; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties; or (d) to prevent physical harm to an individual or financial loss.

Aggregated / Anonymous information. In addition, we may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction.  This includes reporting information to Customers of the Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service.

Opting Out of Marketing Communications

If you receive marketing or promotional communications from us, you may unsubscribe at any time by following the instructions contained within the communications or by sending an email to the address provided in the “Contact Us” section of our website or this Privacy Policy.

Your Choices and Opting-Out of Interest-Based Advertising and Analytics

You can control how you share your Personal Information with us, including electing to opt-out of interest-based advertising altogether. Please visit our opt-out page to opt-out. Generally speaking, an opt-out allows you to direct us not to engage in a particular type of Personal Information collection. There are many different ways that we collect Personal Information, different purposes for that collection, and different industry-specific tools for opting-out. We describe below your different options for controlling how we use your Personal Information:

• Web browser: You can opt-out of receiving interest-based ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking on our opt-out page. Please note that this opt-out function is browser-specific and relies on an opt-out cookie. This means that if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.

• Cross Device Opt-Out: As described above in “Use of Information We Collect,” we may link multiple browsers or devices to the cookie ID, hashed email address or other unique identifiers associated with you. If you opt-out on a browser or device and we have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in certain conditions, there may be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.

• Mobile Device Opt-Out: To opt-out of receiving interest-based ads that are based on your behavior across different mobile applications, see instructions for iOS and Android devices:

• iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and

• For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt-out of interest-based advertising.”

• Smart TV Opt-Out: To opt-out of receiving interest-based ads that are based on your viewing behavior and other interactions with connected televisions (or “smart TVs”), see instructions in your television’s privacy controls, and can also refer to the NAI’s connected tv opt-out instructions.

• Industry Opt-Out Tools and Self-Regulation:

• We recommend using NAI’s opt-out tool which will allow you to opt-out of seeing interest-based ads from us and other advertisers. In addition, NAI’s opt-out tool allows you to separately opt-out of “audience matched” advertising through NAI’s opt-out tool. You can also use the email opt-out tool provided by LiveRamp to opt-out your email address from LiveRamp’s database. Note that this “audience matched” information is derived from an email address or information that can be tied to an email address, it is possible to opt-out with an email address. However, please be aware that if you opt-out this way, you will need to submit all email addresses that you use for the opt-out to be fully effective.

• We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt-out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners, via the DAA website.

• Additional Rights of Individuals Residing in the EEA, Switzerland and California: If you are a resident of the EEA or California, you also have additional data protection rights specific to residents of the EEA, Switzerland or California. These are described in “Accessing and Controlling Your Information” (for EEA and Switzerland residents) and “Supplemental Privacy Notice for California Residents” (for California residents).

ACCOUNTABILITY FOR ONWARD TRANSFER

The Website is hosted and the Service is provided in the United States of America. In the performance of our Service and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our organization and to our service providers or agents, in accordance with applicable data privacy laws.  Transfers to third parties are covered by the provisions in this Privacy Policy under Notice and Choice.

We will endeavor to obtain assurances that any such service provider or agent will provide at least the same level of privacy protection as is required by this Privacy Policy and will notify us if it makes a determination it can no longer meet this obligation.

We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of Personal Information from the European Economic Area (“EEA”) and Switzerland.

Where we know that any third party to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to agents, and to the extent we are responsible for the event, we will remain liable should our agents process Personal Information in a manner inconsistent with this Privacy Policy.

DATA INTEGRITY AND PURPOSE LIMITATION

We endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. We will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by us for as long as we retain possession of such information. Our personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. When acting as a provider of Services to our Customers, we endeavor only to process Personal Information that is relevant to our Service, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.

ACCESSING AND CONTROLLING YOUR INFORMATION

EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant controller, since the controller has primary responsibility for your Personal Information.

NOTE: The following paragraphs reflect rights recognized under the GDPR.  Additional access control rights specific to California residents are set forth in a separate section at the end of this Privacy Policy (“Supplemental Privacy Notice for California Residents”).

For Audience Members: When acting as a provider of services to our Customers, we have no direct relationship with Audience Members, and any such individuals who seek access, or who seek to correct, amend, delete, or restrict processing of their Personal Information should direct their inquiries to the relevant Customer which has transferred such Personal Information to us for processing.  We will assist our Customers in fulfilling their obligations under applicable law to respond to such requests by individuals regarding their Personal Information.

For Customers and other Visitors to Our Website: Under laws in certain countries in which we operate, Customers and other Visitors to our Website from those countries have a right to access Personal Information about themselves, and to correct and/or delete Personal Information that is inaccurate, incomplete or outdated, restrict processing of Personal Information, or port Personal Information to another entity. We will, upon request, provide you with confirmation regarding whether we are processing Personal Information about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct and/or delete your Personal Information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, restrict, or port your Personal Information, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

Please note that while any deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose to third parties any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously provided us as to which you have not instructed us to take such action. Please remember, however, that if we have already properly disclosed some of your Personal Information to third parties (other than authorized subprocessors), we cannot access that Personal Information any longer and cannot force the deletion, restriction or modification of any such information by the parties to whom we have properly made those disclosures.

We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

DATA RETENTION

In general, we retain information we collect from you based on the specific types of information described below, at the end of which periods we will either delete or anonymize the information. Notwithstanding the below-described data retention periods, in some cases we store your information for longer periods in backup archives and/or as necessary to comply with our legal obligations and accounting requirements (but only so long as to satisfy such obligations and requirements), provided that in all such cases we will securely store the information and isolate it from any further processing until deletion is possible.

Specifically:

• Customer-Provided Information: For any information that a Customer instructs us to collect or otherwise provides to us in order for us to perform our Services, we retain this information until the Customer asks us to delete this data or for one (1) year following completion of the Services, whichever is earlier.

• Mobile Identifiers and Cookie Identifiers: Cookies we set expire (and are then deleted) 13 months from the last time your device last accessed the relevant website page where the cookie was set. The expiration period for mobile identifiers is controlled by you on your own device.

• Other Information Associated with Mobile and Cookie Identifiers Related to Browsing History: We delete information associated with mobile and cookie identifiers after 12 months.

• Information Associated with the Display of Ads: Data logged for the display of an advertisement (including cookie identifiers, the advertisement displayed to you and data indicating whether you clicked on the particular advertisement) are deleted after 12 months.

RECOURSE, ENFORCEMENT AND LIABILITY

We encourage you to raise questions about our processing or disclosure of your Personal Information by contacting us, as set forth in the “Contact Us” section below.

We will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Any of our personnel that we determine are in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment, where applicable.

FEEDBACK

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat information therein in accordance with this Privacy Policy.

THIRD PARTIES NOT GOVERNED BY THIS PRIVACY POLICY

This Privacy Policy addresses only our use and disclosure of information we collect from or about you. The use and disclosure restrictions contained in this Privacy Policy do not apply to any third party and we do not control the privacy policies of third parties. The Service and Website and content on them may contain links to other sites and resources controlled by third parties. In addition, if you disclose information to others, including to other uses, you are subject to the privacy policies or privacy statements of those third parties where applicable. We are not responsible for the privacy practices or content of these other sites or resources, and you should consult the privacy policies or privacy statements of such other sites and resources.

DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the information we process, We maintain appropriate administrative, technical and physical safeguards to protect information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection, encryption and other access and authentication controls.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your information has been compromised, please contact us as set forth in the “Contact Us” section below.

We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

In compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Website and the Service are all directed to people who are at least 13 years old or older.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is subject to revision from time to time on a going-forward basis. We will post any revised version of the Privacy Policy on this page. If we make any material changes to it, we may also send you notice thereof to the last email address you have provided to us. Continued use of the Website and/or the Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CONTACT US

If, for whatever reason, you have any questions, comments, complaints or compliments about the privacy of the Service or this Website, please contact our email support. Please also use this email address if you believe you have received a marketing communication from us that you feel makes use of your information in an unauthorized or unwelcome way.  Please contact us using the information below:

http://www.untu.us

3500 South DuPont Highway

Dover, DE 19901

[email protected]

(202) 888-7780

Supplemental Privacy Notice for California Residents

In addition to the information contained above applicable to all users of our Website, this Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Sensitive Data and Sensitive Health Data

Certain information that we collect from third parties may also be considered “Sensitive Data.” Sensitive Data may include social security numbers and bank or credit card account information. Sensitive Data may also include information about your race or ethnicity, or personal health and medical information such as information on personal health conditions and treatment (“protected health information” or “PHI”), prescriptions for medications and laboratory results (“Sensitive Health Data”).

Please click on the following link for examples of the categories of Sensitive Health Data that we collect from third parties, including from our Customers and other trusted sources, and that we use for our Services, both “standard” or “off-the-shelf” audience segments and “custom” audience segments used for the same purposes: https://untu.us/audience-segments/

Please be aware that, unless appropriately de-identified, PHI collected by us may be protected under the Health Insurance Portability and Accountability Act of 1996, as amended.

Information We Collect

Our Website collects Personal Information. In particular, our Website has collected the following categories of Personal Information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA’s scope, including:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

1. We obtain the categories of Personal Information listed above from the following categories of sources:

   • Directly from our Customers or their agents. For example, from documents that our clients provide to us related to the Service for which they engage us.

   • Indirectly from our Customers or their agents through their use of our Service. For example, data about Audience Members we collect from our Customers through their user of our Service.

   • Directly and indirectly from activity on our Website. For example, from submissions through our Website’ portals or website usage details collected automatically.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.

• To provide you with information, products or services that you request from us.

• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

• To improve our Website and present their contents to you.

• For testing, research, analysis and product development.

• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

• Category A – Identifiers

• Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

• Category F – Internet or other similar network activity.

• Category K – Inferences drawn from other Personal Information.

We do not sell, rent or otherwise disclose Personal Information collected by our Service to third parties in the ordinary course of business. However, certain third party agents and other third parties performing services for us may have access to Personal Information in order to do their jobs.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.

• Service providers.

• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:

• The categories of Personal Information we collected about you.

• The categories of sources for the Personal Information we collected about you.

• Our business or commercial purpose for collecting or selling that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you (also called a data portability request).

• If we sell or disclose your Personal Information for a business purpose, we will provide two separate lists disclosing:

  • Sales, identifying the Personal Information categories that each category of recipient purchased; and

  • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at [email protected]

• Using the contact form available at http://www.untu.us

Only you or a person registered with the California Secretary of State 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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: UNTU.us
Email: [email protected]
Postal Address:
3500 South DuPont Highway
Dover, DE 19901
(202) 888-7780