Effective Date: June 15, 2020
Please note that this policy does not apply to information that we collect about you offline including when you telephone us to sign up for our services.
1. Table of Contents
Information We May Collect About You
How We Collect Your Information
Cookies and Automatic Data Collection Technologies
How We Use Your Information
Disclosure of Your Information
Children’s Online Privacy
Social Networks, Third-Party Links, Forums
Your Rights and Choices
Your California Privacy Rights
2. Information We May Collect About You
We collect, use, store or transfer various different kinds of information from you, about you or about your Equipment when you use our Services, including:
- Contact information such as your name, mailing or delivery address, email address, telephone number, or similar contact information.
- Unique identifiers including online identifier, IP address, mobile device identifiers, username, Social Security number, driver’s license number, passport number or similar identifier.
- Internet or other similar network activity including your browsing history, search history, information about your interactions with our websites, applications, or advertisements.
- Technical information such as your internet protocol (IP) address, your login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services.
- Profile information such as your username and password, your interests, preferences, feedback, survey responses, and other similar information.
- Usage information including information about how you use our websites, apps, products, and services.
- Marketing and communications information such as your preferences in receiving marketing from us and your communication preferences.
Some of the information we collect about you may be personal information that can be used to identify you including – for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. However, in no instance does personal information include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose. In addition, Empower may receive data from third party partners, including Cuebiq. See Cuebiq policy here.
3. How We Collect Your Information
We collect information from you in different ways and from different places, including:
- You provide it to us directly. You may give us information about you by filling in forms or by communicating with us by text, e-mail, or otherwise. This includes information you provide when you create an account, purchase and use our products and services, complete a survey, provide feedback, report a problem or otherwise contact us about our Services, or provide information to be published or displayed on public areas of our Services or transmitted to others.
- We automatically collect using technology from our websites, applications, and emails. As you interact with our Services, we may automatically collect technical data about your Equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, web beacons, and other similar technologies (see Cookies and Automatic Data Collection Technologies).
- From other places. We may receive information about you from other companies and individuals including, for example, business partners, subcontractors, advertising networks, social network platforms, analytics providers, and service providers. We may also receive information about you from other users if, for example, another user is engaging in transactions (selling or buying) on your behalf.
4. Cookies and Automatic Data Collection Technologies
- Estimate our audience size and usage patterns.
- Store your preferences so we may customize our Services according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Services.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information, see Interest-Based Advertising.
The technologies we use for this automatic data collection may include, among others:
- Flash Cookies. Certain features of our Services may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the Services. For information about managing Flash cookies see Your Rights and Choices.
- Web Beacons. Our Services pages and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Services content popularity or verifying system and server integrity.
We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.
5. How We Use Your Information
We use your information to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the information we collect include:
- Send you products or to provide you with services that you have ordered, including to process payments and provide you updates about the status of your order.
- Deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging.
- To respond to your requests from us or to fulfill any other purpose for which you provide it.
- Use data analytics to improve our Services, products or services, marketing, customer relationships, and experiences.
- Carry out our obligations and enforce our rights.
In any other way we may describe when you provide the information.
6. Disclosure of Your Information
We may share information that does not identify you without restriction. We may disclose personal information as follows:
- To our contractors, service providers, and other third parties we use to support our business and who are obligated to keep personal information confidential and use it only for the purpose for which we disclose it to them.
- To a seller or buyer with whom you are engaging in a transaction via our Services, or to other users of our Services in connection with the features and benefits we offer (e.g., providing sellers information on who has viewed their listing, providing prospective buyers information on sellers within a listing, etc.).
- With your consent.
- For any other purposes that we disclose when you provide the information.
- To fulfill the purpose for which you provide it.
- To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.
We may also disclose personal information to others:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.
- To investigate suspected violations of any law, rule or regulation, or the terms or policies for our Services.
7. Children’s Online Privacy
We do not direct our websites or services to minors, and we do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through the Services. If we learn we have collected or received personal information from a child under 13 without appropriate consent, we will delete it. If you believe we might have any information from or about a child under 13 please contact us at firstname.lastname@example.org.
8. Interest-Based Advertising
Our Services may integrate technology of third-party advertising networks (“Ad Networks”) that allows for the recognition of your Equipment and the collection of information about the browsing, searching and other activities of you or anyone else using your Equipment. This information is then used to send you advertisements for products and services that are more likely to be of interest to you. For more information on how this type of advertising works, go to www.aboutads.info
To enable interest-based advertising across your Equipment and software, we may also share data, such as technical identifiers derived from your registration information on our Services or our CRM system, with these Ad Networks. This allows them to link your Equipment, browser, etc. and to better identify you across different environments.
If you do not wish to participate in interest-based advertising via Ad Networks, you may opt-out by visiting and following the instructions set forth at either: (1) the Digital Advertising Alliance’s website (www.aboutads.info); or (2) the Network Advertising Initiative’s website (www.networkadvertising.org/choices). A couple of important notes about these opt-out tool: (i) it includes all the advertising networks that we may work with, but also many that we do not work with; and (ii) it may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found on www.aboutads.info. Therefore, if you use different Equipment, change web browser or delete these Opt-out Cookies, you will need to perform the opt-out task again.
Finally, please note that certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for interest-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Unfortunately, given how preference-based advertising works, DNT Notices may not effective in communicating your preferences. For this and a variety of other reasons, with respect to our Services, we do not take any action based on browser based DNT Notices. Rather, if you do not wish to participate in interest-based advertising activities, you should follow the simple opt-out process identified above.
9. Social Networks, Third-Party Links, Forums
Our Services may integrate social network plugins, include links to third-party websites or services, or provide you the opportunity to post content. Please keep the following in mind:
- Third-party links. Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to read the privacy statements of all third-party websites before submitting any personally identifiable information through these websites.
10. Your Rights and Choices
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information:
- Marketing. If you do not want us to use your email address or other contact information to promote or recommend our own products and services, or third parties’ products or services, you can opt-out by ultilizing the unsubscribe mechanism in any emails we send or by contacting us as set forth below in the Contact Us section. If you have an account with our Services, you may be able to log in and check or uncheck relevant boxes. If you do not have an account, you can adjust your preferences by contacting us as set forth below in the Contact Us section. Please note that opting out of marketing communications will typically not apply to transactional communications we send (e.g., purchase confirmations, receipts, account information, etc.).
- Accessing, updating and deleting your information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, you can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
- Location Information. When you use our Services, particularly Application(s), we may automatically collect certain Equipment (mobile device) specific information. This includes the general or specific location of your Equipment through GPS, Bluetooth or WiFi signals. Before we collect or send location-specific information, it is our practice to ask for your consent. In some instances, your operating system may not allow you to install an Application without giving us consent. In all instances, you may withdraw your consent by disabling location features for your Equipment.
- Interest Based Advertising. Please see Interest-Based Advertising above for information on how to opt-out of interest-based advertising.
11. Your California Privacy Rights
If you are a California resident, you may have additional personal rights and choices with regard to your personal information. Please send any requests you may have in this regard in writing to the address provided in Section 14 below. In your request, please attest to the fact that you are a California resident and provide a current California address for our response.
12. Data Security
The security of your information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your information from loss, misuse and unauthorized access, use, alteration or disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
14. Contact Us
Empower MediaMarketing, Inc.
15 E 14th St.
Cincinnati, OH 45202
ATTN: Chief Privacy Officer
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.
15. Sole Statement