Privacy Policy

Choozle, Inc. (“Choozle,” “we,” “our,” “us” or “company”) is committed to respecting the privacy and security of your personal information. The following privacy policy (“Privacy Policy”) describes the information we collect and how we use it. By using this website (“Site,” “Platform,” “Website”) or the service offered through our Site or any mobile application (the “Service”), you consent to our Privacy Policy.

We may periodically update this Privacy Policy to reflect material changes in how we collect, use, share or store your personal information. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current Privacy Policy. You consent to any changes we make to this Privacy Policy if you continue to use the Choozle service after receiving a notice of the change or upon our posting of the new Privacy Policy on this Site.

COLLECTING INFORMATION

Like many websites, we gather information about how visitors use our Site. In general, you can visit many of our web pages without telling us who you are or revealing any personal information about yourself. We may track your visit for trends and statistics, but you will remain anonymous unless you tell us who you are. Once you choose to give us your personal information, you are not anonymous to us.

The following are the types of information we collect:

• Information you give us: We receive the information you provide to us when you register for, or otherwise use, the Site such as your name, email address, business name, business URL, business industry, business type, phone number, address, credit card information and any feedback, questions, or recommendations you provide. If you provide information directly to us in other ways, such as by sending us an email or filling out a form, we may retain that information and add it with the other information we have collected from you. We may also collect information from you that is necessary for our legitimate interests, which will be disclosed to you at the time of collection. Choozle will use this information for the purposes of which it was collected.
• Information from third parties: We may receive information about you from other sources, such from friends who refer you to us, third-party sites, or services that you link your Choozle account with, or otherwise. We may add this information to the information we have already collected from you.
• Information shared with third parties: We may share information about you with other sources, who are both controllers and processors of data required for the management or use of the Choozle platform. Choozle confirms with all third-parties to ensure the data is managed in a lawful manner. Suppliers and service providers are required by contract to keep confidential the information received on our behalf, and may not use it for any purpose other than to carry out the services they are performing for us. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Automatically collected information: To make our Site and Services more useful to you, our servers (which may be hosted by a third-party service provider) may collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name,  precise location data with GPS or lat/log, or a date and time stamp for your visit. We also use Cookies (as defined below) and navigational data to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Like most Internet services, we automatically gather this information and store it in log files each time you visit our Site or access your account on our network. “Cookies” are small pieces of information that a Site sends to your computer’s hard drive while you are viewing a website. Cookies are refreshed from the last time we see a user in order to retain up-to-date information. 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) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable cookies, some areas of our Site or portions of the Service may not work properly. We also could use data from mobile applications, including advertising IDs and mobile device IDs, to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Mobile advertising IDs or Mobile Device IDs are a unique identifier which can be used to identify a mobile device. Mobile applications and networks assign unique identifiers for mobile app developers can identify who is using their mobile apps as well as use for advertising purposes. We interpret engaging with our brand as an indication of your interest in our products and services, and thus providing consent for this data collection. Forms of engagement can be best exemplified by visiting our site, following us on social media, or interacting with our other marketing channels.
• Information collected through our service: Our service allows our clients to collect information about their current or potential customers using cookies, pixel tags, web beacons, web bugs, televisions or OTT devices, and other collection technologies. While we do not collect this information on our site, we want you to be aware of how our services can be used to collect your information using publically available data and other collection technologies. Our clients may provide us with various data sets that typically reside within their customer resource management databases (which may include names, emails, addresses, or phone numbers), which we enable, on their behalf, and help link to applications that they use. We may also collect your location information, such as your zip code or the approximate geographic area derived from your IP address or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled. We also source matched or linked data that enables our clients to pseudonymously match users across channels. The matched or linked data comes from reputable data providers, brands, and websites with the rights to share consumer data. We combine and measure these data sets against each other to ensure a high level of accuracy. When a consumer visits one of our match partner sites (such as a popular website), that partner sends us a unique identifier that has been de-identified using a hashing algorithm. We then search our database of client data to determine whether any of our clients is requesting to match data for that particular consumer. If a match occurs, we associate a cookie with de-identified data about the consumer on behalf of our clients based on the last time we saw a user. Clients can then reach our matched non-personally identifiable users with relevant messages and advertisements. They may also use this data for measurement purposes such as understanding how digital advertising spend impacts purchasing on their Site. Sometimes, we use our mobile cookie or mobile ID data alongside our web-based cookie data, to help other platforms to “match” or “map” users they have already “seen” across multiple web and mobile platforms, on a de-identified basis. This collected data may be used for personalized Advertising or Ad Delivery and Reporting which is further defined under the NAI’s Viewed Content Advertising Guidance. 
• Information used for personalization: As required under the NAI Code, the Choozle discloses standard interest segments that are based on health related information or interests and political information or interests. that it makes available in the Platform where permitted by law and self-regulatory rules. This information is used in the personalization of advertising efforts. Choozle confirms that any data used or collected by Choozle and our partners is obtianed from responsible sources that provide users with appropriate levels of notice and choice.

USING INFORMATION

We use and disclose your personal information only as described in this Policy or as otherwise disclosed to you on our Sites. By registering for our products and services, or engaging with our brand, you provide us consent to collect and use your personal information to provide an enhanced experience with us.  

For example, we may use or disclose your personal information:

• To operate and improve our Sites;
• To fulfill your requests for certain products or services;
• To provide you with content and information relevant to your interests in our product and services to facilitate and enhance your use of the platform;
• To better understand your needs and provide you with more customized service;
• To communicate with you about the Sites or our products and services;
• To respond to any questions or concerns that you may have;
• For market research, project planning, troubleshooting problems, detecting and protecting against errors, fraud, or other criminal activity;
• To third-party contractors that provide services to us and are contractually bound to safeguard your personal information (i.e. credit card processors);
• To third parties in connection with any merger, acquisition, reorganization, change in capital structure or sale of all or substantially all of the assets of Choozle.
• When we have a good faith belief that disclosure is necessary to comply with the law, protect or defend our rights or the rights of other users of our Sites or products or services, or act in an emergency to protect someone’s safety; or
• Otherwise with your express consent.

We may create non-personally identifying anonymous or aggregate data from the information we collect. We may use that data that is non-personally identifiable, pseudonymous or aggregate data for our own purposes or disclose it to third parties in our own discretion.

Do Not Track. We do not respond to browser-based “do not track” signals. We do not have any third-party sites who push content to our site.

PROTECTING YOUR INFORMATION

We have implemented commercially reasonable security measures, including physical, electronic, and administrative safeguards, to prevent unauthorized access to, loss, misuse, or alteration of the information collected through our Websites.  We take reasonable steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We make no assurances in this policy about our ability to prevent such loss, misuse, to you or to any third-party arising out of any such loss, misuse, or alteration. If you have any questions about the security of our Sites you can contact us using the information provided below.

RETENTION

We retain the PII you provide to us for as long as your account is active or as needed to provide you services or perform the purposes for which it was supplied. We will retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We retain the pseudonymous data collected on our Websites for up to 12 months. After 12 months (or sooner) the data is de-identified or aggregated and stored for up to 3 additional years.

THIRD PARTIES

Advertisements and Links to Other Websites: The Site may contain links, content, and advertisements from third parties. Such links, content, and advertisements are not endorsements, authorizations or representations of our affiliation with that third party. We are not responsible for the privacy practices or the content of third parties, and we encourage you to carefully review the privacy policy of any website you visit.

Company Websites may contain content or pixels from 3rd party providers including Analytics, Social Media and Ad Tech partners. Choozle  follows the Digital Advertising Alliance Self-Regulatory Principles and the Network Advertising Initiative Code of Conduct. We may allow certain third parties to collect data about your web viewing behavior on Company Websites and combine this data with information collected from other websites over time for purposes that include interest-based advertising.

There are other limited circumstances in which we may share data. We may provide access to the non-personal information we collect to service providers who are assisting us with storage, analysis, or other services. These service providers are subject to confidentiality restrictions and are not authorized to utilize the information in any way other than to provide their services to us.

We want you to feel confident using the Choozle Site but we cannot ensure or warrant the security of any information you transmit to us.

INFORMATION COLLECTED THROUGH THE USE OF OUR PLATFORM ON THIRD-PARTY SITES

Our technology platform, branded “Choozle” enables companies to gain unique insights about their website visitors, social networks, customers and prospects, and to deliver relevant advertising and content to their browsers. As part of Choozle’s commitment to respect privacy concerns and implement industry-recognized standards, Choozle complies with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising, which are designed to inform consumers about data collection and advertising practices across multiple websites and to provide consumers the ability to opt-out. Choozle is a member of the Network Advertising Initiative (“NAI”) which is an industry association that issues self-regulatory advertising principles. We comply with the current NAI Codes of Conduct.

Find out more information about NAI and the Codes of Conduct here: www.networkadvertising.org.

Find out more information about DAA and the Self-Regulatory Principles for Online Behavioral Advertising here: www.digitaladvertisingalliance.org.

To learn more about our involvement with and adherence to industry standards, please contact us at privacy@choozle.com.

Advertising agencies, advertising networks, and other companies who may place advertisements through our Service (but not on our Site) may use their own cookies, pixel tags, web beacons, web bugs, mobile IDs,  precise location data, TV/OTT viewership, user IDs and other technology to collect information about you. We do not control these companies’ use of such technology and we have no responsibility for the use of such technology by these companies to gather information about you.

YOU SHOULD REVIEW THE PRIVACY POLICY AND TERMS OF USE FOR ANY SITE YOU VISIT TO LEARN ABOUT WHAT INFORMATION THOSE SITES COLLECT FROM YOU, AND HOW THEY USE AND SHARE SUCH INFORMATION. THE INFORMATION IN THIS PARAGRAPH MAY NOT REFLECT WHAT OUR CLIENTS OR WE COLLECT ON ANY INDIVIDUAL SITE.

We and our clients collect, organize, and use non-personally identifiable information reflecting your interactions with a variety of websites, media types and social networks. This information includes items such as the date and time you visited a website, your browser information, your IP address, your precise location data, your TV/OTT viewing behavior,  your browsing behavior, your age and gender, and interests you express or imply at social networking sites or other websites you visit. Choozle or its clients may recognize your computer over time by setting a unique browser “cookie” or “mobile ID,” which your browser relays to our servers when you visit websites that are affiliated with our partners or clients. We and our clients may also supplement the information we collect with additional non-personally identifiable information we obtain from other companies. In certain of these cases, the information we or our clients obtain from third parties is derived from personal information and de-identified prior to its use. We analyze the non-personal information we collect or obtain from third parties and organize it into pseudonymous user profiles, groups, and audiences, based on factors such as age, gender, geography, interests, offline and online actions. We and our clients and partners then use these pseudonymous user profiles, groups, and audiences to design and deliver customized advertising campaigns or other relevant content. We and our clients also use this data for other related purposes (for example, to do research regarding the results of our online advertising campaigns or to better understand the interests or activities of website visitors.)

The behavioral categories we use to customize the ads you may see or for related purposes do not use personally identifiable information (PII) such as your name, address, e-mail address, phone number, birth date, or social security number. Our technology and services are designed to limit our use of consumer data to pseudonymous, non-personal information. Note that we license Choozle to third parties, such as website publishers and marketers. A third-party licensee using Choozle may elect to collect, manage, and use other types of data through Choozle, which may include personal information (where permissible). Please consult the privacy policies of the websites you visit to become familiar with their privacy practices.

Below, we provide you links where you can opt-out by specific companies. You can opt-out by clicking and following the instructions provided. Note that after choosing to opt-out, if you use a different computer or a different browser, or if you delete or block browser cookies, you may need to repeat the opt-out steps. Most Web browsers also enable you to block browser cookies. You can refer to your web browser’s documentation to get more information on how to block or delete cookies directly through your browser settings.

• You can opt-out via the Network Advertising Initiative opt-out at www.optout.networkadvertising.org
• You can opt-out via the  Digital Advertising Alliance (DAA)’s YourAdChoice opt-out at www.youradchoices.com/
• You can opt-out via the Consumer Choice Page at www.aboutads.info
• For those in Europe, you can opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu

You can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser.

When you visit a website that shares information about your activity with Choozle, we will use that information to customize relevant ads to you at that and other websites you visit, or for research and analysis. We may also share non-personal information with companies such as advertisers, agencies, ad networks, or exchanges to enable them to analyze user behaviors or to customize the ads that you encounter.

In addition, we provide you links where you can opt-out with your mobile ID by specific companies as this is handled separately from web-based browsers. This opt-out process will need to be done on your mobile device as it is unique to your device.

• You can review the process on mobile ID opt-out via Network Advertising Initiative here: https://www.networkadvertising.org/mobile-choice 
• You can review the process on mobile app opt-out via the Digital Advertising Alliance (DAA) here: www.youradchoices.com/appchoices

In addition, to comply with the California Consumer Privacy Act (CCPA), the Company must include details on the opt out of the sale of personal information by some or all of the participating companies.

• You can opt-out of the sale of data via Privacy Rights https://www.privacyrights.info/.

HOW TO REVIEW, MODIFY OR DELETE YOUR INFORMATION

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us or would like to update or change your personal information or preferences, follow the instructions below to review, modify or delete your personal information.

To modify the information you have provided during registration, please log in and update your personal settings.

• To unsubscribe from a promotional email, please follow the instructions or unsubscribe links available in any email you receive. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, or to ask you to rate a product you purchased.
• If you request your registration information be deleted or if you unsubscribe from communications, we may maintain information about sales transactions or service inquiries for future service and record keeping purposes.
• To be removed from our cookie-based data segmentation, which is hashed an anonymized, steps must be taken by the individual to be removed from these data sources. You can opt-out via:
  • The Network Advertising Initiative opt-out at www.optout.networkadvertising.org
  • The Digital Advertising Alliance (DAA) opt-out at www.optout.aboutads.info
  • The Consumer Choice Page at www.aboutads.info
  • The IAB Europe’s industry opt-out at www.youronlinechoices.eu

In addition, you can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser.

We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access. When updating or deleting your information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable laws.

We generally retain your personally identifiable information as long as necessary in order to provide you with our services, but after one (1) year we will not use your information for any interest-based advertising or ad delivery. We may retain anonymized or aggregated data generated from your information indefinitely.

THE EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS

Choozle is a global company headquartered in the United States. If you access the Platform or any other Sites managed by Choozle, be aware that your information may be transferred to, stored, and processed in the United States. We transfer personal information from the EU or Switzerland to the US in accordance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Choozle has certified to the Department of Commerce that it adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List, here: https://www.privacyshield.gov. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Choozle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Choozle is responsible for the processing of personal information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as a service provider on its behalf. Choozle complies with the Privacy Shield Principles for all onward transfers of personal information from the EU, including the onward transfer liability provisions. In certain situations, Choozle may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under the Privacy Shield, we commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at privacy@choozle.com or at the address listed in the “COMPLAINTS” section of this Policy. If Choozle does not resolve your complaint, you may submit your complaint free of charge to ICDR/AAA (https://www.icdr.org/), Choozle’s designated independent dispute resolution provider. Under certain conditions specified by the principles of the EU-US and the Swiss-US Privacy Shield Frameworks, respectively, you may also be able to invoke binding arbitration to resolve your complaint.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please contact us by mail or email at:
Choozle, Inc. 2245 Curtis St. Suite 200, Denver, Colorado 80205
privacy@choozle.com

A NOTE TO USERS OUTSIDE OF THE UNITED STATES

Choozle is based, and the Platform is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service to the extent permitted by applicable law.

CALIFORNIA VISITORS

The Choozle Site and Platform follows the  IAB CCPA Compliance Framework for Publishers and Technology Companies v1.0 as a guideline for technical specifications as well as a continued compliant partner of the Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA), which manages Choozle’s cookie-based and device ID opt-out processes.

As it relates to personal data collected on this site for Residents of the State of California, as outlined in the California Consumer Privacy Act (CCPA, you are granted: 

(a) the right to access;

(b) the right to restrict processing, opt-out;

(b) the right to object to processing, do not sell;

(d) the right to disclosure of intent and third parties; and

(e) the right to withdraw consent.

Residents of the State of California may request access to any personally identifiable data that is collected through the Choozle Site. This includes a list of all third parties to which a Choozle Site has disclosed certain information during the preceding year for the third parties’ direct marketing purposes. The Choozle Site does not explicitly sell any personally identifiable data to other businesses or third parties for monetary or other valuable consideration. In the normal course of business and direct marketing purposes, anonymous non-PII cookies are shared between providers to execute digital advertising. 

For California residents that want access to a list of the data, a list of third-parties used, and opt-out of processing and selling, please contact us at privacy@choozle.com.

For all requests, you must put the statement “Your California Privacy Rights” in the body of your request and include the name of the Site with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

DISPUTE RESOLUTION

If you have any questions or concerns, please contact Company by e-mail at privacy@choozle.com. We will do our best to address your concerns and we will process your request within 30 days of receiving it. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and Company are unable to reach a resolution to the dispute, you and Company will settle the dispute exclusively as set forth in the Terms of Service.

CHANGES TO OUR POLICY

We may revise this policy at any time. Any changes and/or updates to the policy will be updated directly on this page. Material changes to this policy will be enacted on a going-forward basis.

EUROPEAN VISITORS

In accordance with applicable laws, you may have the right to request access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. Where any processing of personal information is solely dependent upon your consent, you have the right to withdraw such consent at any time (For example, we suggest by using the unsubscribe link contained in an applicable marketing message or emailing us at privacy@choozle.com). Where you believe that we have not processed your personal information in accordance with applicable laws, you may lodge a complaint with the respective supervisory authority or data protection regulator. The provision of personal information by you will be for contractual, marketing, analytical purposes, or other purposes as referred to in this Policy. When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. Residents of the European Economic Area (EEA), in conjunction with the General Data Protection Regulation (GDPR), may opt out of our cookie-based marketing efforts by using the IAB Europe’s industry opt-out at www.youronlinechoices.eu. Additional specific requests of data collection, management or use may be directed to us at privacy@choozle.com.

CALIFORNIA VISITORS

Residents of the State of California may request a list of all third parties to which a Choozle Site has disclosed certain information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at privacy@choozle.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request and include the name of the Site with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

TERMS OF SERVICE

Please also visit our Terms of Service at https://choozle.com/terms-of-service that explains other terms governing the use of our website.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please contact us by mail or email at:
Choozle, Inc. 3513 Brighton Blvd #510, Denver, CO 80216
privacy@choozle.com

COMPLAINTS

We are committed to working with you to obtain a fair resolution of any privacy concern. If you have a data privacy complaint, please contact us by mail or email at:
Choozle, Inc. 3513 Brighton Blvd #510, Denver, CO 80216
privacy@choozle.com

Effective date June 30, 2020