Great Giveaways Website Privacy Policy

Last modified: April 29, 2014

This Privacy Policy (“Policy”) identifies the privacy practices for the website www.Great-Giveaways.com (the “Site”), including the types of information we collect via the Site and how we use, share, and protect such information, as well as the choices you may make about how we use this information. This Policy applies to all visitors to the Site (“Users”) and not to any other application, website or service. In this Privacy Policy, “the Site”, “we”, “us”, “our” and other similar references mean Great-Giveaways.com, a property of Wave Harmonics LLC and “you” and “your” and other similar references mean a specific user of the Site. Please read the Policy carefully before providing any information. By accessing the Site or providing any information via the Site, you agree to our use of that information consistent with this Policy. While we encourage our partners to comply with best practices regarding consumer privacy, we are not responsible for the privacy practices of any third party product with which the Site may be bundled.

About Great Giveaways

Great Giveaways helps companies and brands improve their marketing based on insights from the online behaviors and overall profiles of millions of consumers who use our services or have joined our panels. Leading advertisers, agencies and publishers rely on Great Giveaways' research services to create engaging online experiences and effective advertising campaigns. Great Giveaways is located in Cambridge, Massachusetts. For more information, please visit great-giveaways.com.

Information Collection

User Statistics. When you visit our Site, we automatically collect information about your visit using tracking technology, including your Internet Protocol address (“IP Address”), a unique device or user ID, system and browser type, the referring address website, the content and pages that you access on the Site or mobile application, and the dates and times that you visit the Site. As discussed below, we use technology, including cookies, web beacons, and other similar technology, to automatically collect certain non-personally identifiable information for system administration, troubleshooting, and to identify you when you visit our Site through your computer or mobile device so that we can enhance your online experience and make our advertising more relevant.

Personally Identifiable Information You Provide Us. For the purposes of this Privacy Policy, “Personally Identifiable Information” is any information that identifies you and is not generally available to the public. We may collect one or more pieces of Personally Identifiable Information that you knowingly supply on the Site’s pages. These data fields may vary based on your path through the Site or based on the kind of Site experience you are seeking. For example, Personally Identifiable Information includes, but is not limited to, a personal email address that you provide to us in order to request email notifications and/or access to certain features of the Site. We also collect and store Personally Identifiable Information that you provide when you register to use any application functionality on our Site, ask a question, complete a form, conduct a transaction, or send us an email. Please be advised that you are not obligated or required to submit any information via our Site; however, if you do not provide the requested information, you may not be able to access or use certain features and functions of our Site and we may not be able to provide you with certain services.

Cookies. Our Site may use cookies.  Cookies are small text files that websites place in your browser when you visit them. When you return to the site, the site can access its previously placed cookie to uniquely identify your browser. Cookies accomplish several different things. They recall your preferences at a website, help content render more efficiently, and improve the overall user experience on a website. They can also help advertisers see what interests you and what advertising may be relevant to you.  Our cookies do not collect Personally Identifiable Information; the information collected is in an aggregate, non-identifiable form. We do, however, store a unique identifier in the cookie that may tie back to a consumer record in our databases that contains Personally Identifiable Information you have voluntarily provided us.  When you visit the Site, we also capture the user agent string from your device which helps us classify the type of device you are using to interact with the Site (e.g. desktop, tablet, mobile device). The user agent string does not, however, collect any Personally Identifiable Information.

By using the Site, you agree to the use of cookies in accordance with this Policy.  If you do not agree to this use of cookies, please disable them.  In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” menu).  Disabling a cookie or category of cookie does not delete the cookie from your browser; you will need to do this yourself from within your browser by choosing the option to delete cookies.  If you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information. Third party sites may also provide additional opt-out methods. Please be advised that, if you do choose to disable cookies, certain features of the Site may not be available to you and we may not be able to provide you with certain services.

Data From Other Sources. We may collect information from third party websites with whom we connect. For example, if you connect to our site via Facebook, Facebook provides us with certain information from your Facebook account, which may include, without limitation, your Facebook User ID, amount of activity (i. e., comments, likes) that may occur in response to posts, certain demographic information and other information, to the extent that you elect to make it publicly available on Facebook and/or explicitly opt to make it available to this Site and any Facebook functionality included on the Site.

If you arrive at the Site by “clicking through” from an email or another website, then certain information about you that you provided to that email sender or other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Site in order to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may or may not retain information about you provided to us by other entities. If we do, we will only use it in accordance with this Policy, unless otherwise directed by the applicable entity providing the information. Such information may or may not be associated with other User activity data or personally identifiable information.

In order to provide the services or offers available to you on this Site, we may also supplement your information (whether or not personally identifiable) with information from third party sources with whom we have contracted for the purpose of verifying the contact information you have provided. We may also obtain information about you from other sources, including affiliates, data aggregators, and public databases. The information we collect may be combined to create a more detailed picture of you, which allows us to better understand the products and services you might be interested in. We are not responsible for any actions, content of websites, or privacy policies of such third parties. Check the applicable privacy policies of third parties when providing information via such third party websites.

User Choice and Browser Settings. We support the user’s choice to use their web browsers privately, without the collection of PII or their online habits. In Google Chrome we do not collect user data if a user has enabled an “incognito” window. In FireFox we do not collect user data if a user has enabled a “private” window.

Information Use and Sharing

In addition to any other uses described in this Policy, we may use and share the information (whether or not personally identifiable) that you provide to us to:

  • Generate a personal profile of you to make your next visit to the Site and other sites that are owned or controlled by us more personalized;
  • Complete transactions and/or respond to your requests or for trouble-shooting or system administration purposes;
  • E-mail information regarding the Site, the Site’s contents and features, and associated notifications, updates, promotions and special offers to you;
  • Compile anonymous statistical information and analyses, and provide that anonymous information to third parties;
  • Provide your information to affiliates or third party service providers to fulfill services you have explicitly requested.
  • Provide, sell or rent your information to third parties for advertising purposes.

If you would prefer not to have your information shared with our business partners, affiliated companies or other third parties, you may opt out by emailing privacy@great-giveaways.com. Also, if you are already receiving Great-Giveaways.com emails and no longer wish to receive such communications, simply follow the “unsubscribe” instructions that appear in every great-giveaways.com e-mail, or contact us through privacy@great-giveaways.com to modify your subscriptions.

Additional Disclosures for your Information

We may release account information and other Personally Identifiable Information when we believe release is appropriate to comply with applicable law, to enforce our legal and contractual rights, or to protect the rights, property, or safety of the Site, Users, or others. We may in some circumstances be required to disclose information (including Personally Identifiable Information) in response to requests from law enforcement authorities, or in response to a subpoena or other legal process. We may also turn over information about you if we believe we must do so in order to prevent a violation of the law, and by accepting this Policy, you consent to our right to do so, in our sole discretion. You also consent to our disclosing information about you in the course of legal proceedings if we believe we are legally required to do so, if we reasonably believe that doing so may mitigate our liability, or if doing so will assist us.

At some point, we may establish subsidiaries or other related companies, or merge with or be acquired by another company. When that happens, then we may disclose to them your information (personally identifiable and otherwise), in which case we will request that they abide by this Policy. We may also disclose some Personally Identifiable Information to a potential acquirer, although such disclosure would be subject to normal and customary confidentiality requirements.

Please be aware that our affiliated institutions, promotional partners, advertisers, sponsors, and other third-party web sites accessible through the Site may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on or through linked websites.

YOU SHOULD NOT USE THE SITE OR PROVIDE ANY PERSONALLY IDENTIFIABLE INFORMATION THROUGH THE SITE OR IN CONNECTION WITH THE SERVICES (INCLUDING WITHOUT LIMITATION, SUBMITTING OR POSTING ANY PERSONALLY IDENTIFIABLE INFORMATION TO THE SITE OR IN RESPONSE TO ANY EMAIL OR OTHER COMMUNICATION SENT TO YOU VIA THE SITE OR REGARDING THE SERVICES) UNLESS YOU WOULD LIKE YOUR INFORMATION TO BE USED IN ACCORDANCE WITH THIS POLICY.

Data Security

We have put in place administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. We perform PII filtering on the client machine to prevent unauthorized PII from being transmitted from the user’s machine. Data is encrypted when being packaged on the client machine, and then is further encrypted as a result of using Secure Sockets Layering (SSL), an industry-standard protocol, when transmitting data to our servers. We also employ firewalls to shield data from unauthorized access our servers and data repository. Data files remain encrypted until they are transported securely to our secured servers.

However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Software demonstrates your acceptance of these risks.

Data Retention

We will retain the information described above for as long as the information has value as part of the services we offer to our clients, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. When data is no longer useful or necessary to maintain, we will purge the data from our data repositories and backups. If you cancel your account by following the directions to remove the Software as described above in How to Opt-out from the Panel; Software Removal, we no longer will collect data from you but we will retain and continue to use your data collected prior to your removal of the Software.

Children's Privacy

We do not direct any of our content specifically to minors. The Site is not intended for users under the age of 18, and we do not knowingly collect or use Personally Identifiable Information from users under the age of 18. We encourage parents and legal guardians to monitor their children’s Internet usage and to instruct their children to never provide Personally Identifiable Information though this Site or any other web site without their permission. If we have reason to believe that a child under the age of 18 has provided Personally Identifiable Information to us through the Site, we endeavor to delete any Personally Identifiable Information we have collected about that user.

If you have reason to believe that a child under the age of 18 has provided Personally Identifiable Information to us through the Site, please contact us and we will endeavor to delete any Personally Identifiable Information we have collected about that user.

Privacy Policy Changes

If we materially change this Policy, we will post the changes to this Policy, so that you are aware of what personally identifiable information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Policy at any time, so please review the Site frequently for any changes.  Revised versions of this Policy will be posted on the Site and will be effective when posted. In our sole discretion, a notice will also be posted on the homepage and/or we will give you email notice when any material changes are made to the privacy policy. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted, the changes in any amended or revised Policy by your continued use of our services or the Site.

Contact Us

If we have any personally identifiable information about you, you may correct, update or delete your contact information by contacting privacy@great-giveaways.com. We will respond to your access request within 30 days.

If you have questions related to this policy, the data that has been collected by the Site, or other privacy concerns, please contact us at privacy@great-giveaways.com or by writing to us at:
Privacy Officer, Wave Harmonics, LLC, One Kendall Square, Suite B2106, Cambridge MA 02139.

Wave Harmonics Data Collection Policy

Last modified: June 1, 2014

If you are upgrading the Software from an older version, you agree that after installing this upgrade, your data previously collected by Wave Harmonics under the older version of the Software may be used as described in this Privacy Policy. You may always uninstall the Software by following the instructions provided here.

Wave Harmonics Data Collection Module Download Privacy Policy

This policy describes our data collection and use practices for consumers who download the Wave Harmonics Data Collection Module (DCM) (the "Software"). The Software may have been installed through the Wave Harmonics DCM website, a partner website, or through a partner's software product with which the Software was bundled. This privacy policy applies only to the operation of the Software and not to any other application, website or service. While we encourage our partners to comply with best practices regarding consumer privacy, we are not responsible for the privacy practices of any third party product with which the Software may be bundled.

Wave Harmonics helps companies and brands improve their marketing based on insights from the online behaviors and overall profiles of millions of consumers like you who have joined our panels. Leading advertisers, agencies and publishers rely on Wave Harmonics' research services to create engaging online experiences and effective advertising campaigns. Wave Harmonics is located in Cambridge, Massachusetts. For more information, please visit waveharmonics.com.

Information Collection

We may collect both non-personally identifiable information and personally identifiable information from you as described below.

Our Software primarily collects 'clickstream data'. Clickstream data is non-personally identifiable information generated by you and your computer while surfing the Internet and interacting with various sites and services. Clickstream data may be collected, stored, combined with other information you have directly provided us or our partners, aggregated into anonymous consumer segments, and used for business and marketing purposes, such as maintaining and improving the Software, conducting research, and monetization.

In greater detail, the Software collects the following types of information:

  • Online browsing: This includes the sites you visit, including news sites or social networks, and your interactions with those sites.
  • Online activities: This includes the URLs for search terms you enter, the videos you view, the products you shop for online, non-secure information you enter into forms, the materials you download or upload, and the advertisements you see including parameters and data passed along with site requests (subject to the filtering process described below in the section entitled "Protecting Personal & Sensitive Information; Information Filtering").
  • Cookies: This includes the domain and cookie name, but does not include actual values within the cookies.
  • System information: This may include information about the computer and browser that you are running on, including the IP address of the computer, how the Software is operating, and which other applications are installed or running. This is used for diagnostic purposes.

Protecting Personal & Sensitive Information; Information Filtering

The Software and our internal systems are outfitted with technical privacy rules designed to avoid the collection of certain types of personally identifiable and sensitive information that can be identified by the Software and systems, such as credit card numbers, social security numbers, email addresses and information from most web-based email accounts. These rules rely on known field types, values, and algorithms, but they are not foolproof, and sometimes the Software may inadvertently collect unwanted information.

As part of our security program, we conduct regular checks to update and refresh these rules that filter personally identifiable and sensitive information. We also use privacy rules within our internal network environment in an effort to prevent the unauthorized use of personally identifiable and sensitive information.

When your information is sent over the public Internet by the Software, it is transmitted through a secure means of data encryption. This is to protect against the information we collect from our panelists being improperly accessed by third parties during such transmission.

Despite our efforts, certain personally identifiable or sensitive information might be collected by the Software and get through the privacy filters and be transmitted to us, such as health and financial details. However, we do not knowingly use any inadvertently collected personally identifiable or sensitive information in our services.

Cookies

We may collect certain information through the use of a web technology called a "cookie." A cookie is a small text file that is saved to your computer using your web browser, which allows websites to recognize you and store preferences and other information if you return to the website using the same computer and browser. The Software does not collect the actual values stored in the cookies.

We may use temporary session cookies during the download and registration process to correctly identify the research panel that you have joined, enable the creation of a unique, anonymous identifier and to trigger the download process.

We may use cookies apart from the Software and link that data to other data in your profile, including data that is collected through your use of the Software.

You may remove cookies and/or control their operation by adjusting your browser settings. Please visit the 'help' section of your browser for more information.

Information Use and Sharing

This section describes how your data – which includes web use, demographic information, and information we have obtained from third parties – contributes to the kinds of services our clients buy from us. Our typical process is to combine panel members' data into consumer segments and report on the aggregated (or grouped) results. Consumer segments are pools of users who have common interests or characteristics, for example, "women between the ages of 28-34 interested in travel websites." Once aggregated, the results and consumer segments are shared with our clients and other parties. On some occasions, we may share non-aggregated results for limited purposes. The following are examples of the kinds of services we provide, and how your data is used in these services:

Advertising Research - Your data is combined with data from other users into a pool that is then analyzed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, Wave Harmonics can help advertisers understand the effectiveness of their ads.

Media Use Analysis - Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analyzed on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content and advertising that they see. For example, we help companies understand the effectiveness of their websites by comparing how users are interacting with their websites versus how users are interacting with their competitors' websites.

Profile Building - We may use the personally identifiable information you have provided to us outside of the Software or an anonymous identifier associated with you (such as an IP address or similar identifier) to get additional information about you from other public and private data sources. These third party data sources may provide us information on your purchases (both online and off-line), your household and lifestyle information, and broader demographic and personal history details. We may combine this information with other information to create and enhance profiles that are shared as described in this Privacy Policy. For example, by looking at both web browsing activity and in-store purchases, our research may identify a consumer segment whose members visit certain websites when they are in the process of researching a product (like a television, computer, or automobile) but are likely to make the actual purchase in a physical store. This data can help the manufacturer or seller of that product better understand where to find customers who may be interested in their products.

Consumer Analysis - We may use your data, including personally identifiable information we have obtained directly or through a trusted third party vendor, to enhance our or our customer's consumer segments explained above. We use personally identifiable information in this way when our customer already has this information because it is usually the only way to match our profiles with those of our customers. Sometimes we may gather information from your clickstream data, such as a session ID, and share it with a third party in order to match your information with the information possessed by a third party as part of our services. Although in each of these cases we permit these other parties and our customers to use your information to enhance their broader consumer segments, to which they then may target advertising, we prohibit these parties from using your information to target advertising to you individually. So in the normal course of your web browsing, you may be a member of a broader consumer segment that sees particular advertising that your data helped create.

Software Diagnostics - We also may use your information for purposes of maintaining the configuration and proper functioning of the Software, for database or Software application services (such as customer support, email, or surveys), and for purposes of data quality and data cleansing.

As part of the registration process prior to installation of the Software or other service with Wave Harmonics, we may directly collect information such as your email address, birth year, household information, income, gender, and ethnicity. This information is part of your consumer profile and used as described above. Of course, the contact information you give also helps us reach you with information related to Software maintenance and upgrades and other service related communications.

When working with a third party to supplement your profile, we protect your privacy by having our partner sign a confidentiality agreement stating that they will not share personally identifiable information with unauthorized parties. We instruct them to maintain the confidentiality, security and integrity of the information we provide and not to use the information for any purpose other than those we explicitly authorize.

We may share information about you with authorized vendors and service providers in connection with the services that they perform for us. These third parties are prohibited from using your information for other purposes.

Additional Disclosures for your Information

In the event Wave Harmonics goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information may be among the assets transferred.

We also reserve the right to disclose your information as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.

How to Opt-Out from the Panel; Software Removal

For users who have downloaded the Software directly from Wave Harmonics, you can opt-out of the Wave Harmonics research panel at any time by removing the Software from your device. For instructions on how to do so, please read the Wave Harmonics Opt-Out and Software Removal Instructions.

In cases where the Software is integrated into a partner's application (such as a toolbar), you can opt-out of the Wave Harmonics research panel, either by removing the partner application or by disabling the collection features of the application if the partner has provided such functionality.

If you are not able to quickly and easily opt-out from the panel or data collection, we can and will help you if you ask. If you have any questions regarding removal or opting-out, you should contact us at privacy@waveharmonics.com.

If you have set your browser to "private browsing" or a similar setting, the Software will not collect clickstream data to be sent to Wave Harmonics.

To completely stop the operation of the Software and the collection of data from your computer, you must follow the instructions above to remove or disable the Software.

Data Security

We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Software demonstrates your acceptance of these risks.

Data Retention

We will retain the information described above for as long as the information has value as part of the services we offer to our clients, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you cancel your account by following the directions to remove the Software as described above in How to Opt-out from the Panel; Software Removal, we no longer will collect data from you but we will retain and continue to use your data collected prior to your removal of the Software.

Children's Privacy

For the majority of our recruitment, the Wave Harmonics research panel consists of users who are of the legal age of majority within their geography. On occasion, we may recruit children for a non-adult panel for custom research. In these cases of non-adult recruitment, we will obtain parental consent and adhere to the appropriate data laws and regulations, including the Children's Online Privacy Protection Act.

Privacy Policy Changes

If we are going to use your information in a manner materially different from that stated in our privacy policy at the time of collection, you will be notified via email or via the Software by Wave Harmonics or by our data partner directly. You will have a choice as to whether or not we use your information in this different manner and instructions for how to make that choice will be included in the notification.

If we make any non-material changes to our privacy practices that do not affect information already stored in our database or for future collection, we will post a prominent notice on our website notifying our members that there is a change and pointing them to the revised privacy policy.

Contact Us

If we have any personally identifiable information about you, you may correct, update or delete your contact information by contacting dcmsupport@waveharmonics.com. We will respond to your access request within 30 days.

If you have questions related to this policy, the data that has been collected by the Software, or other privacy concerns, please contact us at privacy@waveharmonics.com or by writing to us at:

Privacy Officer, Wave Harmonics, LLC, One Kendall Square, Suite B2106, Cambridge MA 02139.

WaveHarmonics Email Data Collection Service Privacy Policy

Last modified: July 23, 2013

Thank you for taking the time to read our Privacy Policy. We want you to have the information you need to understand how we collect, protect, and use email data.

This policy describes our data collection and use practices for consumers who authorize the WaveHarmonics Email Data Collection Service (EDC) (the "Service"). This privacy policy applies only to the operation of the Service and not to any other application, website or service.

Maintaining your privacy is critical to retaining your trust and we employ both technology and process solutions to protect that privacy. For more details, please refer to the "Protecting PII & Certain Other Sensitive; Information Filtering" section below. If you have questions related to this Privacy Policy, the data that has been collected by the Service, or other privacy concerns, please contact us at privacy@waveharmonics.com. We're here to help.

Our goal is to make marketing better. Wave Harmonics helps companies and brands improve their marketing based on insights from the online and email behaviors and overall profiles of users like you who have joined our panels. Leading advertisers, agencies and publishers use WaveHarmonics' research services to create engaging online and email marketing experiences and effective advertising campaigns. WaveHarmonics is located in Cambridge, Massachusetts. For more information, please visit http://www.waveharmonics.com/.

Information Collection

With your permission, we connect with your email account and scan messages to collect information about marketing emails you receive. The information we collect is for the purpose of analyzing email marketing practices. The information we collect includes the title, subject, and header of emails, as well as in what folder the emails were placed by you. Any Personally Identifiable Information (PII) such as a user's email address is removed and the anonymous data is aggregated with the data from other inboxes to analyze and develop business intelligence.

In greater detail, the Service collects the following types of information:

  1. mailbox status for marketing emails: Our marketing campaigns are encoded to allow for the Service to identify emails originating from our partners. The Service also employs algorithms for identifying marketing emails from other marketers. The Service captures the name of the folder where these emails were placed. (E.g., in Inbox, Spam or Delete)
  2. email header data: This data is captured to assist in identifying marketers and marketing related content, such as custom headers used to store marketing and sender related information.
  3. message title and subject: We collect information from the message title or subject to help identify marketing campaigns. We attempt to identify and remove any personally identifying data from the title. We do not capture data from the body of the message.
  4. non-identifying features: This is information parsed from the message body. An example is the presence of an unsubscribe link.
  5. User Profile: As part of the registration process prior to installation of the Service or other services with WaveHarmonics, we collect information that comprises your User Profile. Your User Profile includes your email address and may include demographic information:
    • email address: This information is captured during the registration process and is used by the Service to access a user's email account. The anonymized data is never combined with a user's email addresses to identify a single individual. However, it may be used to acquire additional 3rd party data such as demographic information.
    • demographic information: As part of the registration process we may also request other demographic information such as birth year, household information, income, gender, and ethnicity.

Protecting PII and Certain Other Sensitive Information; Information Filtering

The Service and our internal systems are outfitted with technology designed to avoid the collection of PII and certain other sensitive information such as credit card numbers, social security numbers, and information from supported web-based email accounts. This technology relies on known field types, values, and algorithms, but it is not foolproof, and sometimes the Service may inadvertently collect unwanted information.

As part of our security program, we conduct regular checks to update and refresh these rules that filter PII and certain other sensitive information. We also use privacy rules within our internal network environment in an effort to prevent the unauthorized use of PII and certain other sensitive information.

When the Service collects email data over the Internet, the data is transmitted through a secure means of data encryption. This is to protect against the information we collect from our users being improperly accessed by third parties during such transmission.

Despite our efforts, certain PII or certain other sensitive information might be collected by the Service and get through the privacy filters and be captured by the Service. However, we do not knowingly use any inadvertently collected PII or certain other sensitive information in our services. Such records will be expunged upon discovery.

The User Profile, includes PII and sensitive information that is provided with your permission during registration. It is maintained separately from your anonymized email data and used for service and maintenance purposes as well as profiling purposes such as identifying data associated with a gender.

Information Use and Sharing

The data that we share is aggregated, anonymized (non-personal) information which may be combined with web use, demographic information, and other information we have obtained from third parties. This data contributes to the kinds of services our clients buy from us to improve their marketing practices.

Our typical process is to combine the anonymized email user data into user segments and report on the aggregated (or grouped) results. User segments are pools of users who have common interests or characteristics, for example, "women between the ages of 28-34 interested in travel websites." Once aggregated, the results and user segments are shared with our clients and other parties. The following are examples of the kinds of services we provide, and how your data is used in these services:

Advertising Research - Your anonymized data is combined with data from other users into a pool that is then analyzed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular message with another group of users who did not see that message, WaveHarmonics can help marketers understand the effectiveness of their campaigns.

Service Support - The information that comprises your User Profile helps us reach you with information related to Service maintenance and upgrades and other service related communications.

PII Use and Sharing

Other than the specific instances listed here we do not share your PII with 3rd parties.

Service Providers: We may share your PII with authorized vendors and service providers in connection with the services that they perform for us, such as data processing or technology services. These third parties are prohibited from using your information for other purposes.

Corporate Change: In the event WaveHarmonics goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your PII may be among the assets transferred.

Legal Compliance: We also reserve the right to disclose your information, including PII, as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.

How to Opt-Out from the Panel; Service Removal

At any time, you can opt-out of our service. For users who have opted into the Service directly from WaveHarmonics, you can opt-out of the WaveHarmonics research panel at any time by going to www.waverharmonics.com/edc_disable.html for instructions. Please read the WaveHarmonics Opt-Out for Data Collection Service Instructions.

If you are not able to quickly and easily opt-out from the panel you should contact us at privacy@waveharmonics.com. We can and will help, if you ask.

After opting-out, your information will be subject to retention in accordance with "Information Retention," below.

Data Security

We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Service demonstrates your acceptance of these risks.

Information Retention

We will retain the information described above for as long as the information has value as part of the services we offer to our clients, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you cancel your account by following the directions to remove the Service as described above in How to Opt-out from the Panel; Service Removal, we will no longer collect information from you but we will retain and continue to use your information collected prior to your cancellation of the Service.

Children's Privacy

The WaveHarmonics research panel consists of users who are of the legal age of majority within their geography. We adhere to the appropriate data laws and regulations, including the Children's Online Privacy Protection Act and do not knowingly collect personal information from children.

Privacy Policy Changes

If we are going to use your information in a manner materially different from that stated in our privacy policy at the time of collection, you will be notified via email or via the Service by WaveHarmonics or by our data partner directly. You will have a choice as to whether or not we use your information in this different manner and instructions for how to make that choice will be included in the notification.

If we make any non-material changes to our privacy practices that do not affect information already stored in our database or for future collection, we will post a prominent notice on our website notifying our members that there is a change and pointing them to the revised privacy policy.

Contact Us

If we have any PII about you, you may correct, update or delete your contact information by contacting support@waveharmonics.com. We will respond to your access request within 30 days.

If you have questions related to this policy, the data that has been collected by the Service, or other privacy concerns, please contact us at privacy@waveharmonics.com or by writing to us at:

Privacy Officer, WaveHarmonics, LLC, One Kendall Square, Suite B2106, Cambridge MA 02139.