Effective Date: March 18, 2015
Predictable.ly Inc. (“Predictable.ly”, “we”, or “us”) values your privacy. We are a technology company offering a set of web-delivered tools and services for publishing and media organizations (collectively, “Clients”) to analyze and predict internet traffic, user interests, and other content based interest. Clients, their end users, as well as other web surfers whose digital data is processed by Predictable.ly as part of its provision of services to its Clients (collectively, “Users”) must be able to trust that their data is processed by Predictable.ly in accordance with applicable privacy laws and regulations.
Information We Collect
We collect two types of data about individuals: (1) information that you or others voluntarily submit to us (“User-Supplied Information”) and (2) technical data automatically collected from all visitors to the Website, and individuals that use Predictable.ly to send or receive emails (“Passive Data Collection”).
We may collect User-Supplied Information, including but not limited to, the following scenarios:
- If you choose to subscribe to the Predictable.ly service and become a Client, you will be asked to provide information such as first and last name, email address, time zone, and the company you are with (including your position). We will also ask you to create a username and password for your account.
- When you choose to provide us with your Personal Information via the Website or in any other manner, including when you send us an email asking a question or submit a form to receive marketing and promotional materials.
- If you choose to further customize any of the system and its preferences associated with your account with Personal Information such as a mailing address.
Predictable.ly may monitor the internet traffic, contents of emails and messages sent, as well as stories or other content recommended via Predictable.ly, but is not obligated to do so, and may not.
Passive Data Collection
The table below explains the cookies we use and why.
|JSESSIONID||For security reasons when logging in a session cookie is needed. It is a unique id to this session and encrypts this in a cookie. This cookie is set when logging in and will be deleted when logging out.|
|GlobalSessionId||A session cookie to keep you logged in into the old and the new system at the same time|
|test||To check if cookies are disabled or not in the browser. To inform the user that cookies has to be enabled for the signup and be able to login|
|__utmz||Keeps track of where the visitor came from, what search engine they used, what link was clicked on, what keyword they used, and where in the world they are when they accessed the website.|
|_utmv||Stores information used within Analytics to identify user as part of a custom segmentation.|
|_utmc||Holds timestamp of the exact moment in time when a visitor leaves the site|
|_utmb||Holds timestamp of the exact moment in time when a visitor first visits the site|
|_utma||This cookie keeps track of the number of times a visitor has been to the site, when their first visit was, and when their last visit occurred.|
|hblid||A visitor identifier used to remember the visitor between visits|
|wcsid||A session identifier used to keep track of a single chat session|
|olfsk||Storage identifier used to maintain chat state across pages (e.g. message history)|
|_okbk||Extra state information (e.g. chat box being open/closed)|
|_ok||Most recent Olark site ID (security measure)|
|_oklv||The Olark loader version (for improved caching)|
We may use a variety of data analytics products and services to analyze Users’ use of the Website and services offered. The analytics products and services provides us with aggregated data in order to help us make informed business decisions.
You can configure your Internet browser (Internet Explorer, Mozilla Firefox, Google Chrome, Safari, Opera, etc.) by changing its options, to stop accepting cookies completely or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions of the Website or all functionality of Predictable.ly.
How We Use Personal Information
We use Personal Information to establish and enhance our relationship with you. We may use Personal Information to operate, provide, improve, and maintain Predictable.ly, and to develop new products and services; to prevent abusive and fraudulent use of Predictable.ly and the Website; to personalize and display content on the Website; to send you information about products and services (including our products and services) in which we believe you may be interested; and for other administrative and internal business purposes. Some user account information may be kept indefinitely for purposes of Predictable.ly’s business records.
We may use Passive Data Collection to: (a) remember your information so that you will not have to re-enter during your visit or the next time you visit the Website; (b) customize our services to you; (c) monitor aggregate website usage metrics such as total number of visitors and pages viewed; and (d) administer, operate, and improve Predictable.ly and the Website and our other services and systems, and to provide services and content that are tailored to you.
When We Disclose Personal Information
We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. This may include responding to legal requests from jurisdictions outside of the United States, where we have a good faith belief that the response is required by law in that jurisdiction. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Predictable.ly Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of Predictable.ly, any individual, or the general public; maintain and protect the security and integrity of our services or infrastructure; protect ourselves and our services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
Change of Ownership
In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to, another entity, we reserve the right to transfer all of your Personal Information, including email addresses, to that entity. We will use reasonable efforts to notify registered users of any such transfer to an unaffiliated third party (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).
The security of your information is VERY important to us, including, but not limited to, the Personal Information collected via Predictable.ly and the Website. We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information.
As part of our security, we restrict access to Personal Information to Predictable.ly employees, contractors and agents who need to know that information in order to operate, develop or improve Predictable.ly. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using Predictable.ly or the Website or by providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of Predictable.ly.
If a security systems breach occurs, we may post a notice on our homepage (www.predictable.ly) or elsewhere on the Website and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. This notice paragraph applies to users of Predictable.ly and the Website. Should there be a breach that affects your end users, you will be responsible for disseminating notice of such a breach to your end users.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Predictable.ly and the Website are not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personally identifying information through our websites. Additionally, we do not knowingly collect or maintain Personal Information from anyone under the age of 13, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has registered on the Website or you believe has otherwise provided Personal Information to Predictable.ly, please contact Predictable.ly at firstname.lastname@example.org to have that child’s account terminated and information deleted. Clients are responsible for ensuring that they are in compliance with COPPA, Predictable.ly is merely acting at the direction of our Clients and as an agent of our Clients.
Where it is required by law or where Predictable.ly otherwise deems it appropriate, Predictable.ly will seek consent from you before Predictable.ly processes your data (opt in). Predictable.ly reserves the right not to provide you with certain products or services should you choose not to provide required Personal Information.
You may, at any time, update, correct, or delete certain Personal Information that you have provided to us by contacting us at email@example.com. You are entitled to request that Predictable.ly shall not process your personal data for direct marketing purposes. Additionally, Clients may, at any time, review, and update or correct the Personal Information in their registration profile.
You can choose to delete your account from within Predictable.ly or by emailing firstname.lastname@example.org. We will make every effort to delete all User history within thirty (30) days of when the account is deleted. Please be aware that even if you update or remove Personal Information that you have provided to us, including if you delete your account, your Personal Information may be retained in our backup files and archives for a reasonable period of time for security and legal purposes.
Administrative Communications and Marketing Communications
If you registered on our Website, or otherwise opted in to receive communications from us, we may send you administrative messages and updates regarding your account, updates regarding Predictable.ly or the Website, and information regarding offer, products and services from us, including, without, limitation, through social media updates and by email. You may indicate your preferences regarding commercial email messages by taking the steps described in such messages. Also, you may indicate your preferences regarding commercial email messages by contacting us using the information in the “Contact” section.
Predictable.ly and the Website may contain links to websites and services provided by third parties. Any Personal Information you provide on third-party websites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security.
California Privacy Rights
California’s “Shine the Light” law permits residents of California to request certain details about what personal information a company shares with third parties for the third parties’ direct marketing purposes. The request can be made once a calendar year and includes information only from the prior calendar year (e.g. requests made in 2013 will receive information regarding 2012). Predictable.ly does not share your information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission. To obtain this information, please write to us at 20 N. 3rd Street, Unit 701, Philadelphia, PA 19106 or email email@example.com with “Request for California Privacy Information” in the subject line.
Predictable.ly complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area member countries and Switzerland. We have certified that we comply with the Safe Harbor Frameworks and adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement.
Predictable.ly conducts in-house verification of its compliance with the Safe Harbor Privacy Principles. For any complaints regarding our compliance with either of the Safe Harbor Frameworks, please contact Predictable.ly at firstname.lastname@example.org. If after submitting a complaint to Predictable.ly the issue cannot be resolved through Predictable.ly’s internal processes, individuals may submit the complaint to JAMS for mediation pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr/rules-international-rules. JAMS mediation may be commenced as provided for in the JAMS International Mediation Rules. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Information who has brought the complaint. Predictable.ly will assume the costs of the administrative fees if the mediator makes a written recommendation that finds Predictable.ly in breach of its duties pursuant to the Safe Harbor Privacy Principles. Mediation will be conducted in the English-language. Complaints involving Predictable.ly’s human resources data may be submitted to the European Union Data Protection Authorities (“EU DPA”) or the Swiss Federal Data Protection and Information Commissioner (“Swiss FDPIC”), as applicable. Predictable.ly agrees to cooperate and comply with the EU DPA and the Swiss FDPIC to investigate unresolved complaints involving Predictable.ly human resources data. All other disputes will be handled as indicated above.
For more information about the U.S.-EU Safe Harbor Program, the U.S.-Swiss Safe Harbor Program, and to view our certification, please visit http://export.gov/safeharbor/. You may view and learn more about Predictable.ly’s compliance with these Safe Harbor programs at www.predictable.ly/safe-harbor-policy.
Privacy Questions / Feedback