IGNITE OPM PRIVACY POLICY

Revised: January 1, 2020

It is important that you fully understand what happens to the information we gather from you as an advertiser or other user of IgniteOPM’s (“Ignite”) website and services. Please read this Privacy Statement carefully to understand how we will use and protect your personal information.

Collection of Your Personal Information

If you contact us initially on Ignite’s website, we ask for the following information: address and other contact information, website address, a range of annual revenue, the types of advertising channels you are interested in using, a summary of what you would like to discuss with Ignite and how you heard about us.  If you decide to use our services, we will collect additional information from you concerning your business, including, without limitation, products and services, existing online marketing activities, marketing objectives, marketing budget, sales and other financial data, and taxpayer ID number.

When you receive email from Ignite, we may use Web beacons and customized links (or similar technologies) to determine whether the email has been opened and whether you clicked on a link in the email in order to provide you more focused e-mail communications or other information.



Other Users

We collect personal information if you provide information such as your name, e-mail or telephone number in the context of making an inquiry through our Site.

Use of Your Personal Information

We may use all information you provide to render services to you, including, without limitation, providing you with more effective services; making our website easier to use; performing research and analysis aimed at improving our services; and providing you with content and communication that are relevant to your business objectives. More specifically, we may also use your information:

  • To serve your requests and offer our services.
  • To improve customer service.
    • Information you provide helps us respond to your customer service requests, fulfill your requests, and support needs more efficiently.
  • To personalize user experience.
    • We may use information individually or in the aggregate to understand how our users individually or as a group use our services and resources.
  • To improve our Services.
    • We may use feedback you provide to improve our services and website.
  • To send periodic emails, mailings, and contact you telephonically.
    • We may use your contact information to respond to your inquiries, questions, and/or other requests and to send you promotions or other offers that may be of interest to you.
  • To protect against certain activities.
    • We may use your information to protect our website, our partners and affiliates, you, other users, and the public against potentially prohibited or illegal activities, including fraud.
  • To fulfill legal requirements.
    • We may use your information to fulfill applicable legal requirements, such as responding to subpoenas seeking user information.
  • To provide targeted marketing and advertising.
    • We may use your information to send you marketing and advertising from us and our partners and affiliates that we think may be of interest to you. If you do not wish to receive such marketing and advertising, please see our instructions below or follow the opt-out instructions in the marketing or advertising you receive.
  • To conduct research.
    • We may use your information to conduct research and analysis for a variety of purposes, including to better understand our customers, to assist with our current and future service offerings, and to understand our customers and website visitors better.
  • To manage and protect our information technology infrastructure and security.
    • We may use your information to help manage, secure and protect our IT infrastructure and to protect the security of our website.
  • For any other purpose with your consent

For more information about the use of information for communication, see the Communication Preference section below.

Use of Web Beacons

Web beacons, also known as clear gifs, single-pixel gifs, pixel tags, or action tags, are tiny electronic images that we may use in our email communication to let us know if you have opened an email that we sent you or clicked on a link within that email.

Sharing of Your Personal Information

Except as described in this statement or in any agreement that you enter with us, we will not disclose your personal information without your consent. Ignite may disclose personal information if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of Ignite and our affiliates, both publishers and advertisers. Your personal information and other data may be transferred in connection with a business transition, such as a merger, acquisition, insolvency, or asset sale.

We may share with publishers and other third parties certain of your information as necessary to render services to you. We may also hire other companies to provide limited services on our behalf, such as to send email, to perform statistical analysis of our services, to provide support, to carry out invoicing, or to make payments. These publishers, third parties and service providers will be permitted to obtain only the personal information they need to perform their functions. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

Our website may contain links to the sites of third parties. When you visit these sites, please consult those sites’ individual privacy statements in order to determine how they treat user information. Ignite is not responsible for the privacy statements or the content of such sites, and the privacy practices of other Websites and companies are not covered by this statement. We request that users report any and all concerns about our business partners’ privacy practices directly to us as outlined in the Contacting Us section below.



Accessing Your Personal Information

Ignite’s website users and clients are able to change their personal information at any time by contacting us as outlined in the Contacting Us section below.

Communication Preferences

If you do not wish to receive marketing communications from us, you may opt out at any time. These choices do not apply to the receipt of specific administrative notices that are required by law, regulation, or as needed to service your account.

Security

Ignite is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to protect your personal information from unauthorized access, use, or disclosure. Only employees who need the information to perform a specific job are granted access to your personal information, such as our accounting department accessing your information in order to send invoices. Our employees must use password-protected screen-savers when they leave their desks. When they return, they must re-enter their password to regain access.

Accountability for Onward Transfers

To effectively serve the needs of our clients, Ignite may need to share your information with certain third parties or sub-processors. In such instances, Ignite will execute any needed contracts, clauses or addendums to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with this Privacy Policy and the Privacy Shield Principles. Ignite is potentially liable for onward transfers to third parties of personal data of EU individuals received pursuant to the Privacy Shield.

Jurisdiction

Ignite has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Ignite states that if there is any conflict between the terms of our privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Ignite is also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). To learn more about the Privacy Shield program, and to view Ignite’s Privacy Shield certification, please visit www.privacyshield.gov.

Changes to This Privacy Statement

We will occasionally update this Privacy Statement to reflect changes in our services. When we post changes to this Statement, we will revise the “last updated” date at the top of this statement. We encourage you to periodically review this statement to be informed of how Ignite is using and protecting your information.

Recourse & Enforcement

In instances where other redress possibilities have been exhausted under EU law, or where the complaint has not been resolved by any other means, EU end users may be entitled to invoke the binding arbitration option before the Privacy Shield Panel. Ignite acknowledges that any final decision by the Privacy Shield Panel is a legally binding decision, enforceable in US courts.

IGNITEOPM’S PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in Ignite’s above PRIVACY NOTICE and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. NO
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. NO
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. NO
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Our Website obtains the categories of personal information listed above from the following categories of sources:

  • Tracking information received indirectly from forms you complete or products and services you purchase.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us  about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers

Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

  • Emailing us at privacy@igniteopm.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Full name, email address, date & time of transaction
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically in a csv document.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the personal information of consumers.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@igniteopm.com or write us at: 3900 E. Mexico Ave. Suite 400 Denver, CO 80210.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Ignite, LLC collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://www.igniteopm.com/contact-us/

Email: privacy@igniteopm.com

Postal Address:

IgniteOPM

Attn: Privacy Department

3900 E. Mexico Ave.

Suite 400

Denver, CO 80210