Last updated: September 26, 2019
Intent Global, Inc (“Intent,” “we,” or “us”) helps brands deliver tailored content and advertising to people (“Users,” “you,” or “your”) as they use the internet. This document describes Intent privacy practices as they pertain to our corporate websites and any customer extranet (the “Site”); our advertising technology service (the “Advertising Service” or “Intent Global Inc”); our online personalization and customization service (the “Site Customization Service”); our web and app analytics service (“Web Analytics Service”); and how we collect and use consumer data. This policy does not apply to the practices of companies and online properties not under the control of Intent or to individuals that Intent does not employ or manage. Please note that in some cases we serve as a data processor for other companies’ data. In those cases we are bound by the contractual requirements agreed to with those data controllers.
Intent is a member of the Network Advertising Initiative (NAI) and adheres to the NAI’s Self-Regulatory Code. Intent also respects the Digital Advertising Alliance Principles and adheres to the IAB Europe OBA Framework.
Intent is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
EU-US and Swiss-US Privacy Shield Framework
Intent has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
What Information We Collect
Personal data is information that can be used to identify an individual.
We process personal data that Users enter on our Site, send to us via email, or voluntarily provide to us in any other way.
Registering to become a customer of Intent (our “Clients”) requires the submission of personal data, including name, mailing and/or billing address, email address, company name, website URL, credit card, and/or other payment information.
Intent collects personal information from Users in connection with its Site Customization Service when Users voluntarily register on Client online properties. When Users register we may ask for information such as name, email address, country of residence, or postal or zip code.
Intent does not collect any of the following data in connection with the Services: social security numbers or other government-issued identifiers; insurance plan numbers; financial account numbers; information that describes the real-time geographic location of an individual derived through location-based services such as through GPS-enabled devices (though we do collect IP addresses, which can provide approximate geographic location); or precise information about past, present, or potential future health or medical conditions or treatments, including genetic, genomic, and family medical history.
Device-Identified Consumer Data
Device-identified information is information that generally can’t be used by us to identify you personally. In some jurisdictions, device identifiers are categorized as personal data.
We collect device-identified data in connection with our Site and Services. We sometimes enable other third-parties to collect information in connection with our Advertising Service, Intent Global Inc. In order to customize the online user experience and provide our Clients with useful statistics and analysis regarding their online properties and advertisements, Intent may collect certain device-identified information, including but not limited to a User’s purchasing intent, usage information, transaction information, IP addresses, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, and number of clicks. In mobile applications where we have a presence, we may also collect mobile advertising identifiers such as IDFA and Google AdID.
In some cases, we are able to infer within a reasonable probability that a particular computer or mobile device should be associated with the same identifier that we have previously assigned to another computer or mobile device. In other words, in such cases, we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same user. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices and to improve the services we provide to our clients. We refer to this as cross-device advertising.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
How Collected Information Is Used
The data that Intent or its third-party advertising technology vendors collect are used to better predict responses to custom content, to help determine which content performs best, and to evaluate which content is most appropriate for a given User. The data may also be used to target advertisements and other content to people on the Client online properties they visit. In addition, we may use the data to analyze trends, administer the Site and the Services, customize the advertising and content, track Users’ movement in the aggregate, and gather broad demographic information for aggregate use. Data may also be combined with device-identified information collected from other sources to assist with targeting ads to consumers’ preferences and behaviors and for other Intent sales and marketing efforts.
The personal data that Intent collects through its Site Customization Service is used to personalize communication and provide an enhanced user experience on Client online properties. In addition, Users’ information may be used, in accordance with the terms of registration, as part of the marketing programs of the Client on whose online property the information is submitted. Data may also be combined with device-identified information collected from other sources to assist with targeting ads to consumers’ preferences and behaviors and for other Intent sales and marketing efforts.
If a User voluntarily provides Intent with personal data in an email or by completing an online form, we use that personal data only to contact such User to respond to such User’s inquiry.
We use personal data of Clients to service accounts.
Sharing with Third Parties, Onward Transfer
We may employ third-party companies and individuals to process payments, to facilitate the Services, to provide the Services on our behalf, to perform operational services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services’ features) or to assist us in analyzing how our Services are used. These third parties may have access to information we’ve collected but only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Intent may share aggregate information (which does not include device-identified information or personal data) about Clients and Users with advertisers, publishers, business partners, sponsors, and other third parties.
For Users who are explicitly notified during registration for our Site Customization Service, we may share a User’s personal data with the Client on whose online property the registration occurs, as part of the marketing programs of the Client. Clients are bound to use the data only for purposes agreed to by the User and to provide the same level of protection as defined in this policy. Clients are also required to notify Us if they can no longer meet this obligation, in which case they are bound to cease processing the data or take other reasonable and appropriate steps to remediate.
Intent may disclose any information in our systems if we believe that doing so is legally required, including to meet national security or law enforcement requirements, or if it is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of other persons, entities, facilities, equipment or the Services. We may transfer information to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, we will provide a prominent notice on our Site of any change in ownership or uses of information, as well as any choices we may offer regarding the information in our systems.
In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or Swiss-US Privacy Shield, Intent is potentially liable.
Legal Basis within the European Union
We process personal data for our Site, and for our Advertising and Site Customization Services based on user consent (art. 6(1)(a) GDPR), for entering into and the performance of a contract with our customers (art. 6(1)(b) GDPR) and based on legitimate interests (art. 6(1)(f) GDPR).
When processing your data, we pursue the following legitimate interests: Improving our service, protection against abuse, statistics, and the commercial advertising interests of our customers.
Cookies and other Targeting Technologies
Intent employs “cookies” and web beacons in connection with providing the Site and the Services. Cookies are small packets of data, which may include a pseudonymous unique identifier, that are sent to a User’s browser from a server and stored on the User’s computer’s hard drive. The online property placing the cookie on the User’s computer can then recognize the computer when the User navigates the online property at a later time. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/.
Intent may also use statistical IDs in connection with the Services. Statistical IDs are derived from information collected from your computer or device, such as your devices’ IP address, user agent string and types of fonts installed on your computer or device. They don’t install software or leave anything permanently on your computer or device.
The cookies we set in connection with the Services expire after no more than five years, and the expiration date may update every time you encounter our server. Only our opt-out cookie (see below) has a different expiration date. We retain our raw log data, which includes data from the web and from mobile applications from which we receive data, for two years to help us understand historical seasonality trends. We retain our aggregated data, which contains no pseudonymous identifiers or personal data, indefinitely.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. This includes the necessary physical, electronic and managerial procedures to protect data integrity, access and use. This also includes, but is not limited to the use of encryption. Any data that is stored on Intent servers is treated as confidential and is not generally available to the public. Intent has an internal security policy with respect to the confidentiality of customer and other data, limiting access only to those employees who we reasonably believe need to know such information for the purpose of performing their jobs. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect personal data, we cannot guarantee its absolute security. Please send questions about security on our Site to the address in the section “Contacting Us.”
Choice / Opt-out
If you’d like to opt out from having Intent personalize your ads and site content in connection with the Advertising and Site Customization Services, please click here. When you opt out, we will place an opt-out cookie on your computer, which tells our Advertising and Site Customization Services not to use your data to target advertisements or site modifications on your device, and, in Europe, not to process personal data as defined there. Note that you may still receive advertisements or site modifications based on other factors such as your geography and the content of the online property you are visiting. You may also opt out of Intent Global Inc’s behavioral advertising and other companies’ behavioral advertising at YourOnlineChoices.eu in Europe or via the Network Advertising Initiative in the United States. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or internet browser, you will need to renew your opt-out choice.
To revoke consent you may have given Us as part of our Site Customization Service, and/or to opt out of all future transfers of data we may have on you, we encourage you to (1) opt-out of our Services as described above; and (2) request a deletion of the data we have on you as described below in the “Access to Information” section below.
Individuals looking to limit the use of their personal data may contact Intent at the address in the section “Contacting Us,” and we will purge their personal data. Yet for Clients or former Clients, we may not be able to purge the data.
Access to Information
Intent acknowledges the right of individuals to access their personal data in human- and machine-readable formats to the extent it is available and allows the individual to correct or delete inaccurate information.
Individuals should contact us at the address in the section “Contacting Us” to access their personal data that we have for the purpose of viewing, exporting, deleting, or updating that information. Please note that in cases where we serve as a data processor on behalf of a separate data controller, you must direct requests about your personal data to the data controller.
Intent Site or Services may permit Users to link to other online properties on the internet, and other online properties may contain links to the Site. These other online properties are not under Intent ’s control and Intent is not responsible for the privacy or security practices or the content of such online properties.
Intent is very sensitive to the issue of children’s privacy. Intent’s Site and Services are neither developed for, nor directed at, children. If you believe your child has provided Intent with personally identifiable data, or registered at one of Intent Client online properties, and you would like to have the data removed, please contact us.
General Data Protection Regulation (GDPR)
Intent has worked assiduously to prepare for the GDPR and is compliant with the regulation.
For all requests concerning the security of your data, you can contact us via email at email@example.com.
If you have a particularly sensitive request, please contact us via postal mail, as communication by email can always be subject to security gaps.
Intent Global, Inc.
Care Of: Privacy Department
75 Varick Street, 8th Floor
New York, NY 10013