PRIVACY POLICY

This Privacy Policy (the “Policy”) governs how Poln, Inc. (“Company” or “we” or “us”) uses the confidential information we collect about you during your use of our website (the “Site”) and services (the “Services”).  Capitalized terms not defined herein shall have the meaning ascribed to them in the Company’s universal Terms and Conditions.  For detailed information about Company’s services, please refer to the Terms and Conditions and/or the Advertiser’s Terms and Conditions.  This Policy is subject to change from time-to-time without prior notice.

INFORMATION THAT WE COLLECT AND HOW WE USE IT:

·       INFORMATION ADVERTISERS AND PUBLISHERS GIVE US:  When you are using our Site and Services as an advertiser, you must create an account and provide us with your business information, including your name, email address, telephone number or credit card.

·       INFORMATION WE GET FROM YOUR USE OF OUR ADVERTISERS WEBSITES:  When you visit the website of one of our advertisers or clients, we may collect non-personal information about the advertisers you visit.  This information includes information about the device you are using, such as your hardware model, operating system version, browser version, screen resolution, unique device identifiers.  This information may also include the use of one or more cookies or other anonymous identifiers sent to your device, allowing us to collect and store information from your visit to our advertisers’ and clients’ websites.  If you are not aware, cookies are small amounts of data sent to your browser from our Site and stored on your computer's hard drive, which may contain information, such as a unique user ID.

·       HOW WE USE THE INFORMATION:  We use information collected from cookies and other technologies, like pixel tags, to deliver more relevant ads to you while you are browsing.  To be clear, however, when we show you tailored ads, we do not associate a cookie or anonymous identifier with any sensitive categories, such as those based on race, religion, sexual orientation or health.

·       SHARING INFORMATION:  We do not share information concerning our advertisers, clients, or publishers with anyone outside of our Company except anonymously to deliver tailored ads.  We certainly do not use any of your specific information or share it with anyone, except if we believe in good-faith that the disclosure and/or use of your information would be necessary in the following circumstances: (i) we are compelled by a court order or legal inquiry (such as a search warrant, subpoena, or other legal requirement); (ii) if we need to protect from a physical threat to someone or something; (iii) if we need to address a breach or attempted breach of security or confidentiality of our Site; or (iv) if we need to defend or assert our own legal rights or enforce our terms of Service.

·       PROTECTING INFORMATION:  We use industry best practices to ensure that information is kept confidential and that unauthorized access, alterations, or disclosures are prevented.  For example, we encrypt as much of our Services as is practicable, we regularly review our information collection, storage, and processing practices (both digital and physical) and we restrict access to personal information to Company personnel who need to know the information in order to process it, and those individuals are subject to confidentiality obligations.

·       INFORMATION OBTAINED FROM THIRD PARTIES: In order to protect you from fraud or other misconduct, we may obtain information about you from third parties to verify the information you provide. For example, we may use card authorization and fraud screening services to verify that your credit or debit card information and address match the information that you provided to us. We also may obtain information from third parties in connection with providing services to you, such as information arising from transactions using Company’s services.

TRANSPARENCY AND CHOICE

Different people have different privacy concerns.  We do our best to [be?] clear about what information we collect, so that you can make meaningful choices about how it is used. 

You can set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us.  This will prevent you from receiving ads from us that are based on your past behaviors.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

Whenever you use our services as an advertiser or publisher, we provide you with access to your business information through your login and password.  If that information is wrong, we ask that you update it directly.

LIMITS TO YOUR PRIVACY

Our Privacy Policy generally applies to all of the Services we offer except for those certain Services that may have separate privacy policies that do not incorporate this Privacy Policy.  This Privacy Policy does not apply to any third party web sites to which our Site may link, and we are not responsible for the privacy practices or the content of any such third parties.  When you leave our Site and link to another website, you are subject to the terms and conditions of that website, including their privacy policy and terms of use. 

Our Privacy Policy does not apply to services offered by our advertisers, including products or sites that may be displayed to you in ads.  Our Privacy Policy also does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

ENFORCEMENT

We regularly review our compliance with our Privacy Policy.  We also adhere to several self regulatory frameworks.  If we receive written complaints, we will contact the person who made the complaint to follow up. We will then work with the appropriate regulatory authorities, including data protection authorities, to resolve any complaints regarding the transfer of personal or similar data that we cannot resolve with our users directly. 

CHANGES TO THIS POLICY

Please note that this Privacy Policy may change from time to time.  We will not reduce your rights under this Policy without your explicit consent.  We will post any Privacy Policy changes on this page so please check back on a regular basis for updates.  . Each version of this Privacy Policy will be identified at the top of the page by its effective date and we will also keep prior versions of this Privacy Policy in an archive for your review.  If you are an advertiser or client of ours, then in the event of any significant changes to this Privacy Policy, we will notify you through a notice on the Site and/or by email.

If you have any questions about this Privacy Policy, please feel free to contact us through our Site.