PRIVACY POLICY

Updated: October 24th, 2016

What This Privacy Policy Covers

Intent Media, Inc. (“Intent Media,” “we,” or “us”) is a company that helps brands deliver tailored content and advertising to people (“Users,” “you,” or “your”) as they use the internet. This document describes Intent Media’s privacy practices as they pertain to our corporate websites; any customer extranet (the “Site”); our advertising technology service (the “Advertising Service”); our website and wifi portal personalization and customization service (the “Site Customization Service”); and how we collect and use consumer data. This policy does not apply to the practices of companies and websites not under the control of Intent Media or to individuals that Intent Media does not employ or manage.

Intent Media is a member of the Network Advertising Initiative (NAI) and adheres to the NAI’s Self-Regulatory Code. Intent Media also respects the Digital Advertising Alliance Principles and adheres to the IAB Europe OBA Framework.

Intent Media is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

EU-U.S. Privacy Shield Framework

Intent Media complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Intent Media has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Complaint Handling
In compliance with the EU-US Privacy Shield Principles, Intent Media commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Intent Media via email at privacy@intentmedia.com or via postal mail at the address in the “Contacting Us” section of this web page.

Intent Media has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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 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.

US-Swiss Safe Harbor

Intent Media complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Intent Media has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit www.export.gov/safeharbor/

Complaint Handling

In compliance with the US-Swiss Safe Harbor Principles, Intent Media commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Intent Media at privacy@intentmedia.com or via postal mail at the address in the “Contacting Us” section of this web page.

Intent Media has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism 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 www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

What Information We Collect And What We Use It For

Personally Identifiable Information

We collect Personally identifiable information (“PII”) in connection with the Site. PII is information that can be used to identify an individual User, for example, a person’s name, home address, email address, or phone number. We receive and store any PII Users enter on our Site, send to us in an email, or voluntarily provide to us in any other way.

Registering to become a customer of Intent Media (our “Clients”) requires the submission of PII to our company, including name, mailing and/or billing address, email address, company name, website URL, credit card, and/or other payment information. We use this information to service accounts and respond to inquiries. We will only use the contact information of Clients for communications related to our business matters. Registered Clients may reach us through the “Contact Us” links on our Site to update or correct their personal information.

Intent Media does not collect PII from Users in connection with its Advertising Service. Users should be aware, however, that Intent Media’s Clients may request such information from Users in order to use their websites or e-commerce systems. Users should therefore review the privacy policies of the websites they visit to assess the security of any PII they disclose.

Intent Media collects PII from Users in connection with its Site Customization Service when Users voluntarily register on Client websites or wifi portals. When you register we may ask for information such as your name, email address, country of residence, or postal or zip code. If you choose to use Facebook, LinkedIn, or Twitter to register instead of manually entering your data, we may access your general social information in accordance with the respective Facebook, LinkedIn, or Twitter terms, the permission you have granted our application, and your privacy settings.

Sensitive Information

Intent Media 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.

Non-Personally Identifiable Consumer Data

Intent Media collects non-personally identifiable information via the Site. Non-personally identifiable information is information that generally can’t be used by us to identify you personally. We also collect non-personally identifiable data in connection with our Advertising Service and our Site Customization Service, and we sometimes enable other third-parties to collect information in connection with our Advertising Service. In order to customize the online user experience and provide our Clients with useful statistics and analysis regarding their websites and advertisements, Intent Media may collect certain non-personally identifiable 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.

Data Integrity

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 non-personally identifiable data that Intent Media or its third party advertising technology vendors collect are used to better target advertisements and other content to people on the Client websites and wifi portals they visit. The data may also be used to predict responses to custom content, to help determine which content performs best, and to evaluate which content is most appropriate for a given User. In addition, we may use the data to analyze trends, administer the Site and the Services, customize the advertising and content Users may see, track Users’ movement in the aggregate, and gather broad demographic information for aggregate use. We may use different types of technology, including cookies and web beacons (see more information below), to collect such anonymous information and target the most relevant content to Users based on such information. Data may also be combined with non-personally identifiable information collected from other sources to assist with targeting ads to consumers’ preferences and behaviors, and for other Intent Media sales and marketing efforts.

The PII that Intent Media collects through its Site Customization Service is used to personalize communication and provide an enhanced user experience on Client websites and wifi portals. 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 website or wifi portal the information is submitted. Data may also be combined with non-personally identifiable information collected from other sources to assist with targeting ads to consumers’ preferences and behaviors, and for other Intent Media sales and marketing efforts.

If a User voluntarily provides Intent Media with PII in an email or by completing an online form, we will use that PII only to contact such User to respond to such User’s inquiry.

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.

We may also provide the information of Clients to our business partners or other trusted entities for the purpose of providing the Services.

Intent Media may share aggregate information about Clients and Users with advertisers, publishers, business partners, sponsors, and other third parties. Intent Media may share non-personally identifiable information with advertisers, publishers, business partners, sponsors, and other third parties for the purpose of allowing those entities to better target custom content. We do not use information about health-related topics to target ads or other content to Users.

For Users who are notified during registration for our Site Customization Service, we may share a User’s PII with the Client on whose website or wifi portal 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 Media 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 individuals received pursuant to the EU-US Privacy Shield, Intent Media is potentially liable.

User Segmentation

We may also use the data that we collect to aggregate groups of Users, referred to as “segments,” based upon their behavior. We may give our Clients a limited right to use segments as a basis for targeting and displaying advertisements and other content that are intended to reflect the intents and interests of Users associated with a given segment.

Cookies and other Targeting Technologies

Intent Media employs “cookies” and web beacons in connection with providing the Site and the Services. Cookies are small packets of data, which may include an anonymous unique identifier, that are sent to a User’s browser from a website’s computer and stored on the User’s computer’s hard drive. The website placing the cookie on the User’s computer can then recognize the computer when the User navigates the website at a later time. For more information about cookies and web beacons, please visit www.allaboutcookies.org.

Intent Media 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.

Intent Media may use cookies, web beacons, JavaScript and statistical IDs for the purposes of helping us better understand when an internet User has seen or clicked on an advertisement. These technologies will help us tailor advertising messages served via the Services, and for ad delivery and reporting purposes.
Users always have the option to prevent the use of cookies on their computers by changing the setting on their internet browsers to block cookies. In addition, Users have the option to block the use of JavaScript, which may be used by Intent Media to display advertisements. Controlling cookies and JavaScript may not have an impact on our use of Statistical IDs. Since each internet browser is different, for more information, each User should review the documentation regarding the User’s specific browser. Users are encouraged to review their privacy choices below under the section entitled “Choice / Opt-out.”

Users should be aware, however, that blocking the use of cookies or JavaScript may affect the User’s ability to access the functionality and content of certain websites.

Data Retention

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 may retain our raw web log data or aggregated data indefinitely.

Security

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 Media’s servers is treated as confidential and is not generally available to the public. Intent Media 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 PII, we cannot guarantee its absolute security. Please send questions about security on our Site to privacy@intentmedia.com.

Choice / Opt-out

If you’d like to opt out from having Intent Media use your information in connection with the Advertising Service, please click here. When you opt out, we will place an opt-out cookie on your computer, which tells our Advertising Service not to use your data to target advertisements on your computer with data collected from different sites. You may also opt out of Intent Media’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.

Individuals looking to limit the use and disclosure of their personal data may contact Intent Media at privacy@intentmedia.com, and we will purge their personal data. Yet for Clients or former Clients, we may not be able to purge the data.

Users who have authorized our Hotel Guest Connection application to connect via Facebook, LinkedIn, or Twitter who would like to stop providing access to Us should refer to the instructions on the respective social network to update the privacy settings.

Access to Information

Intent Media acknowledges the right of individuals to access their PII to the extent it is available and allow the individual to correct, amend or delete inaccurate information.

Individuals should contact us at privacy@intentmedia.com to access their personal information that we have for the purpose of viewing, and in certain situations, updating that information.

Third-Party Sites

Intent Media’s Site or Services may permit Users to link to other websites on the internet, and other websites may contain links to the Site. These other websites are not under Intent Media’s control and Intent Media is not responsible for the privacy or security practices or the content of such websites.

Children’s Privacy

Intent Media is very sensitive to the issue of children’s privacy. Intent Media’s Site and Services are neither developed for, nor directed at, children. If you believe your child has provided Intent Media with personally identifiable data, or registered at one of Intent Media’s Client websites, and you would like to have the data removed, please contact us.

Changes to This Privacy Policy

Intent Media may find it necessary to update this privacy policy from time to time. We will conspicuously note any material changes and post the changes in this privacy policy on our Site. We reserve the right to modify this privacy policy at any time, so please review it frequently.

Contacting Us

To inquire about privacy concerns, please contact Intent Media by mail at the address below or email us at privacy@intentmedia.com.

Intent Media, Inc.
Privacy Department
315 Hudson Street, 9th Floor
New York, NY 10013
USA