Privacy policy
Last modified: September 20, 2023
Introduction
Cross Commerce Media, Inc. d/b/a/ Collective[i] (“Company”, “we” or “us”) provides several websites, including https://www.collectivei.com, https://intelligence.collectivei.com, https://intelligence.com and https://themodernsale.com (our “Website”), and a network platform and other online solutions that allow our clients to conduct forecasting, contact capture, analytics and other services (the “Network Platform”). For the purposes of this Privacy Policy (“Policy”), we refer to our Website and the Network Platform, and any other products, services, and solutions we provide, together as the “Services.”
We respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy (together with our Terms of Use and any other documents referenced therein or herein) describes the personal information that we may collect from you, or that you may provide on or through our Website, or that we otherwise collect about you in connection with the operation of the Services. This Policy also describes how that information may be used or disclosed by us and the choices available to you regarding your personal information.
This Policy does not apply to information that we may collect through any other means, or to information collected on any other Company, affiliate, or third-party site, or by any third-party application that may link to or be accessible from our Website.
Please read the following carefully to understand our policies and practices regarding your personal information and how we may treat it. This Policy may change from time to time and your continued use of our Services is deemed to be acceptance of such changes, so please check this Policy periodically for updates.
If your company has purchased our Services, then the Services are intended for you as a representative of business and are not intended for you as an individual consumer. Accordingly, we will treat your personal information covered by this Policy as pertaining to you as an individual acting as a business representative, rather than acting in your personal or household capacity.
Personal Information We Collect
We collect several types of information from and about users of our Website, including:
Information that you provide to us. This includes information, such as your name, email address and phone number(s), that you may provide by filling out any form on our Website, including in connection with subscribing to any service offered on our Website, posting any material on our Website, or requesting further information, products or services. We may also ask you for information when you report a problem with our Website.
Information about your business, such as company name, company size, company location and business type, including business information that we may receive from third parties, such as LexisNexis.
Information that we may collect as you access or navigate through our Website, including usage details, IP addresses, and cookies and web beacons.
Records and copies of your correspondence with us (including emails) in the event you contact us.
Your responses to surveys that we might ask you to complete voluntarily for research purposes.
Information Collected Through Our Data Network Platform
We collect information under the direction of our clients, and have no direct relationship with the individuals whose personal information our clients process. Such information may include business information, such as company name, company size, company location and business type; business communications; and contact information, such as a person’s name, employer, job title, email address and phone number(s). Although we have no direct relationship with the individuals whose personal data our clients possess, we acknowledge that you have the right to access your personal information. An individual who seeks access to or who wants to correct, amend, or delete inaccurate data found on our platform and provided by one of our clients, should direct his or her query to our client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We also collect information that individuals chose to contribute directly to our platform through intelligence.com. Such information may include business communications and contact information, such as a person’s name, employer, job title, email address and cell or phone number(s). Such individuals may request access to and may correct, amend, or delete inaccurate data found on our platform by emailing privacy@collectivei.com. If requested to remove data, we will respond within a reasonable timeframe.
Information We Collect Via Log Files, Cookies and Similar Technologies
As you navigate through our Website, for the purpose of system administration and in order to report aggregate information to our advertisers, we may also collect details of your visits to our Website, including, but not limited to, traffic data, location data, logs and other communication data, and the resources that you access, as well as information about your computer and internet connection, including your IP address, operating system and browser type. We may collect this information using cookies and similar technologies, as described in our Cookie Notice below.
Retention of Personal Information
Some data you can delete whenever you like, some data we will delete upon request, some data is deleted by our application automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.
Information retained until you remove it – such as your profile information, privacy settings, and account-related information. We will keep this data in your account until you choose to remove it and/or update it.
Information updated or deleted upon request – such as personally identifiable information that appears on our platform. We allow the “right to be forgotten”. To submit a request, please see “General Data Protection Regulation (GDPR) – European Representative” below or send an email to privacy@collectivei.com.
Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For instance, sales communications that are outdated and no longer useful for machine learning purposes can be deleted.
Information retained until your account is deleted – such as your username, password and log-in information. For security purposes, this information cannot be accessed after your account is deleted.
Information retained for extended time periods for limited purposes – sometimes business and legal requirements obligate us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment for you, we need to retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include: security, fraud and abuse prevention; financial record-keeping; complying with legal or regulatory requirements; and ensuring the continuity of our services.
How We Use The Information Collected
We use personal information in the following ways:
To provide you with our Service in accordance with any contractual requirements, including any terms in our Master Services Agreement or our Terms of Use, as applicable. This includes:
Providing and maintaining the content and functionality of the Services.
Responding to your inquiries, comments, feedback or questions, or processing your requests.
Managing our relationship with you, which includes sending administrative information to you relating to our Services and changes to our terms, conditions, and policies.
Carrying out our obligations arising from any contracts entered into by you and us.
Allowing you to participate in any interactive features that we may offer on our Website, when and if you choose to do so.
To improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users. This includes:
Presenting our Website and its contents in a suitable and effective manner for you and for your computer.
Analyzing how you interact with our Services, and improving and developing the Services.
Aggregating personal information and using the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes.
Preventing fraud, criminal activity, or misuse of our Services, and ensuring the security of our IT systems, architecture and networks (including troubleshooting, testing, system maintenance, support, and hosting of data).
To provide you with information about our products or services. We may contact you to tell you about information we believe will be of interest to you. You may opt out of receiving promotional emails by following the instructions contained in each communication we send to you or by contacting us as explained at the bottom of this Privacy Policy. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding administrative matters, and to respond to your requests. Where required by law, we will only send users marketing communications with your consent. Otherwise, we will market and advertise our Services on the basis of our legitimate business interests.
Disclosure of Your Information
How We Share Personal Information
We may disclose personal information to the following categories of third parties:
Instructions of Customers and Clients. We will disclose your personal information in accordance with a Client’s or Customer’s instructions, including any applicable terms in the Subscription Agreement and/or Terms of Use.
Service Providers. We may disclose your personal information to contractors and service providers we use to support our business or our Website. These companies are authorized to use your personal information only as necessary to provide services to us, which may include but are not limited to payment processing, fulfilling subscription agreements and providing customer service.
Corporate Affiliates. We may disclose your personal information with our corporate affiliates, parents and/or subsidiaries.
Mergers. We may disclose your personal information to a buyer in the event of a merger, divestiture, restructuring, reorganization, dissolution or any other form of sale of some or all of the Company’s stock or assets, whether as a going concern or as a part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about its customers is among the assets transferred. We may disclose your personal information in connection with a merger, divestiture, restructuring, reorganization, dissolution or any other form of sale, to any other third party without your prior written consent.
Legal Disclosure. We may disclose your personal information as required by law, such as to comply with any court order, legal process or other legal obligation, to enforce or apply our Subscription Agreement, Terms of Use and/or other agreements, to protect the rights, property or safety of the Company, our customers or others, which may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
With Consent. We may disclose your personal information with third parties when we have consent to do so.
How You Share Personal Information
You may share personal information through the Services as follows:
User Contributions. The Services may allow you to publish, display or otherwise post content. You are responsible for any content, including personal information, that you choose to post (collectively, “User Contributions”). Your User Contributions may be posted on and/or transmitted to other users of our Website, or others, at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. You understand and acknowledge that, even after removal, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on our Website, including User Contributions, is governed by our Terms of Use and known or suspected violations should be reported to legal@collectivei.com.
Your Privacy Choices
We strive to provide you with choices regarding the personal information you provide to us, and we have created mechanisms to provide you with the following control over your information:
Newsletter(s). If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter(s) to you. You may choose to stop receiving our newsletter(s) or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or contacting us at privacy@collectivei.com
Advertisements. We partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on our Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.
To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices)
European Interactive Digital Advertising Alliance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu)
Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
Personal information requests. We may offer you choices that affect how we handle the personal information that we control. Where required under the laws that apply in your place of residence, you may request the following in relation to your personal information:
Information: You may request information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Policy.
Access: If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. Where applicable, we will provide your personal information in a structured, commonly used and machine-readable format.
Correction: You may request the correction of personal information that is inaccurate or out of date.
Deletion: You may request the deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
Additional rights: In some circumstances, you may object to our use of personal information, ask that we restrict such personal information, or where you have provided your consent to the collection of personal information for a specific use, you may have the right to withdraw consent for that specific use at any time.
Opt out of selling personal information and targeted advertising. We may share information we collect via our website, such as information about the pages you visit on our Website, with our advertising partners to support our interest based advertising, which may qualify as a sale or sharing of personal information, or targeted advertising, under applicable law. To opt out of this use of your personal information, please contact us at privacy@collectivei.com.
To make a request, please use the contact details provided in the “Contact Information” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
In some instances, your choices and rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. Please note, if you have a concern about our privacy practices, including the way we handle your personal information, you can report it to your local data protection authority. We hope you will be able to address any concerns with us directly in the first instance so we are able to respond to them.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Security
The security of your personal information is of the upmost importance to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@collectivei.com.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by using EDPO’s online request form or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
UK General Data Protection Regulation (UK GDPR) – UK Representative
Pursuant to the UK GDPR, we have appointed EDPO UK Ltd (EDPO UK) as our UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by using EDPO UK’s online request form or writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
EU-U.S. and Swiss-U.S. Data Privacy Frameworks
The Company complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. The Company has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Collective[i] has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, the Company commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us at: privacy@collectivei.com
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, the Company commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to https://feedback-form.truste.com/watchdog/request, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of our U.S.-based third party dispute resolution provider are provided at no cost to you.
Under certain conditions, more fully described on the DPF website in Annex I to the DPF Principles, the DPF provides the right to invoke binding arbitration to resolve complaints not resolved by other means.
Persons Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information on or through our Website. We do not knowingly collect personal information from anyone under 18. If you are under 18, please do not send any information about yourself to us, including your name, address, phone number(s) and email address. In the event that we learn that we have collected personal information from a person under the age of 18, we will delete that information. If you believe that we might have any information from or about a person under the age of 18, please contact us at legal@collectivei.com.
Changes to Our Privacy Policy
We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Information
To ask questions or send comments about this Policy and our privacy practices, you may email privacy@collectivei.com or send mail to:
Collective[i]
c/o Legal Department
450 Park Avenue South, 3rd Floor
New York, NY 10016
Notice at Collection
Here is a high-level snapshot of the main ways we use and share the personal information we collect from your use of the Services. For complete information on our privacy practices, please read the Privacy Policy.
How you use the services
When you visit our Website
Identifiers, including IP address and online identifiers. Internet and other electronic network activity information, including automatically collected data, such as internet and usage information, and information collected via cookies and similar technologies.
Geolocation data (e.g., Geo IP). Inferences drawn from the information above.
Primary purpose of processing
To create, fund, maintain, customize, improve, and secure the Services
To market our products and services, including for interest-based advertising
Primary Recipients (Other than Service Providers)
Analytics providers
Advertising networks
Can you Limit Sharing?
Yes See “Your Privacy Choices”
How Long We Retain Personal Information
See “Retention of Personal Information”
When you contact us, sign up for newsletters, create an account, or otherwise use the Network Platform
Identifiers, including name, email, username, official identification information, IP address, and online identifiers. Personal information described in Section 1798.80(e) of the California Civil Code. Commercial information, including transaction information.
Internet and other electronic network activity information, including automatically collected data, such as internet and usage information, and information collected via cookies and similar technologies.
Primary purpose of processing
To create, maintain, customize, improve, and secure the Services, or otherwise provide services you request
To market our products and services, including for direct marketing
Primary Recipients (Other than Service Providers)
N/A
N/A
Can you Limit Sharing?
No See “Your Privacy Choices”
How Long We Retain Personal Information
See “Retention of Personal Information”
Cookie Notice
This Cookie Notice explains how we use cookies and similar technologies.
What are cookies and similar technologies?
Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. We refer to all these technologies collectively as “cookies.”
What types of cookies and similar technologies do we use?
We use the following categories of cookies:
Strictly necessary - These cookies are necessary for the website to function and cannot be switched off in our systems. They allow us to enable security, prevent fraud and debug the website and are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the sites will not work.
Functional - These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Performance - These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around the Services. If you do not allow these cookies we will not know when you have visited our Services and will not be able to monitor performance.
Targeting - These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. Cookies may either be set by us (first party cookies) or by a third party at our request (third- party cookies).
How can you control the use of cookies?
Other than “essential cookies,” which are required to allow our Website to operate, you can limit online tracking by:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies: – Digital Advertising Alliance for Websites: outout.aboutads.info – Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices – Network Advertising Initiative: optout.networkadvertising.org
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.