Privacy Policy

Effective as of January 2018

This Privacy Policy (the “Privacy Policy”) relates to the information collection and use practices of Aetion in connection with our Site (www.aetion.com).

By accessing and using our Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use, which are incorporated herein by reference to form this Agreement. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

The Information We Collect and Receive

In the course of operating the Site, we will collect (and/or receive) the following types of information. You hereby authorize us to collect and/or receive such information.

1. Personal Information. If you contact us, you may choose to provide us with personal information about yourself.  This personal information may include your name, address, e-mail address, and phone number.  The personal information referred to in this Section is called “Personal Information.” We do not collect any Personal Information from you when you visit the Site unless you provide us with the Personal Information voluntarily.  Customers who enter into a License Agreement with Aetion for use of the Platform may be required to provide us with certain additional information, the collection and use of which is governed by the License Agreement.

2. Other Information. We may collect additional information (collectively, the “Other Information”). Such Other Information may include:

a. From You. Additional information about yourself that you voluntarily provide to us, such as your product and service preferences.

b. From Your Activity. Additional information that we automatically collect when you use the Site, including, without limitation: IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; details regarding your activity on the Site, amount of time spent on the Site, pages viewed, and other performance and usage data.

c. About Your Device. Type of device; advertising Identifier (“IDFA” or “AdID”); operating system and version (e.g., iOS, Android or Windows); carrier; and network type (WiFi, 3G, 4G, LTE).

d. From Cookies. We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect data and to enhance your experience with the Site. Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to: authenticate users; personalize your experience; analyze which portions of the Site are visited or used most frequently; and measure and optimize advertising and promotional effectiveness.

If you do not want us to deploy cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still use the Site, although your ability to use some of the features may be affected.

e. Third-Party Analytics. We, the Site, and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, and ad servers with which we work use third-party analytics services (such as Google Analytics) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site.

For Google Analytics, please visit https://www.google.com/analytics

We also use one or more third-party remarketing services (including Google Adwords) to advertise on third-party websites to previous visitors to our Site. These third-party remarketing service providers use cookies to serve ads based on a past visit to the Site. Any data collected by such third party remarketing service providers will be used in accordance with this Privacy Policy and the privacy policy of such third party remarketing services provider. For more information on such third party remarketing service providers, including how to opt out from certain data collection, please visit the following links:

For Google Adwords, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

f. From Other Sources. Additional information that we collect or receive from third-party sources in accordance with their privacy policies.  

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about your activity on the Site with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Site and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us and these third-party advertisers to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. Neither we nor any third party acting on our behalf employs behavioral advertising or retargeting in connection with users whom we know to be under 13 years old.

How We Use and Share the Information  

We use the Personal Information and Other Information (collectively, “Information”) to provide you with access to the Site and the services available on the Site, solicit your feedback, and to improve our services to you. Also, we may share Information as described below, to the extent not prohibited by applicable federal and state laws, rules, and regulations.

In an ongoing effort to better understand our users and our Site, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share, sell, and/or license this aggregate data with our affiliates, agents, and business partners, and other third parties. We may also disclose aggregated user statistics in order to describe our products and Site to current and prospective business partners and to other third parties for other lawful purposes.

We may employ other companies and individuals to perform functions on our behalf. Examples may include companies and individuals providing marketing assistance, information technology support, ID verification, maintaining databases, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. Our contracts with all such third parties require them to protect the confidentiality of the Information we provide to them.

We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

To the extent permitted by applicable law, we may also disclose the Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Aetion, our users, or others.  

If we intend to use your Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Information is collected.

Sharing of Your Information with Non-Affiliated Third Parties

We will not share your Personal Information with non-affiliated third parties that may use such information to market to you, without obtaining your opt-in consent. For example, we may offer you a product opportunity that requires us to share your Personal Information with non-affiliated third parties that may use such information to market to you. We will obtain your opt-in consent to such sharing of your Personal Information when we present you with the terms of such offer.  If you have opted-in for this kind of sharing, then you may: (i) choose to opt-out of such sharing by contacting us at privacy@aetion.com; or (ii) request certain information regarding our disclosure of such information to such non-affiliated third parties by contacting us at privacy@aetion.com.  Further, if you would like to opt-out of Aetion’s sharing of your Information with its affiliates so that such affiliates can use your Information to market to you, please contact us at privacy@aetion.com.

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We maintain physical, electronic, and procedural safeguards that comply with applicable state and federal laws and regulations to guard non-public personal financial information from unauthorized access, use, and disclosure.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to and from us over the Internet.

Accessing and Modifying Personal Information and Communication Preferences

You may access, review, and make changes to your Personal Information by contacting us at privacy@aetion.com.  In addition, you may manage your receipt of marketing communications by clicking on the “unsubscribe” link located on the bottom of any Aetion marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases.

Important Notice to Non-U.S. Residents

The Site and our servers are operated in the United States.  Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Site, you do so at your own risk.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Site. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the Site without their permission.  If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Aetion may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to privacy@aetion.com.

In addition, Aetion does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

External Websites

The Site may contain links to third-party websites. Aetion has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Site as soon as they go into effect.  By accessing the Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at privacy@aetion.com.

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