PRIVACY POLICY

Effective Date: January 24, 2019

This Privacy Policy outlines how Strategic America (“SA,”, “we,” “our,” or “us”) collects, uses, and shares information from any online service location that posts a link to this Privacy Policy, including, without limitation, www.strategicamerica.com, metisadsolutions.com, and ad-grab.com, and all features, content, and other services that we own, control, and make available through such online service locations, including, without limitation, the Metis Software (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection). We urge you to read this Privacy Policy so that you will understand both our commitment to privacy, and how you can participate in that commitment.

By using the Service, you agree to our Terms of Use and to our collection, use, and disclosure practices, and other activities described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.

  1. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If we make changes to this Privacy Policy, we will post the revised Privacy Policy with the date of revision on the Websites and other places we deem appropriate. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address.

  1. INFORMATION COLLECTION
    • A. Information You Provide.

We collect information you provide directly via the Service, such as when you register an account, update your profile, access our content, make a purchase, participate in a sweepstakes, contest, survey, or other promotion (“Promotion”), contact customer support, or apply for a job. We may use Service Providers (defined below) to collect this information.

The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:

  • Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
  • Credentials. We collect passwords, password hints, and similar security information for authentication and account access.
  • Demographic Data. We collect demographic information such as your age, gender, and country.
  • Payment Data. We collect data necessary to process your payment if you make a purchase, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. We may transfer this payment data to third party payment processors to process and store this payment data in accordance with the terms herein.
  • Profile Data. We collect your username, interests, favorites, and other profile data.
  • Content. We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use. For example, if you chat with another user through the Service, we need to collect the content of that chat to display it to you and the other user as you direct.
  • Resume Data. We collect data as necessary to consider you for a job opening if you submit an application to us, such as your employment history, transcript, writing samples, and references.
  • B. Information Collected Automatically.

We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

  • Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information.
  • Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.

We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

  • Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data
  • Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
  • Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.

  • C. Information from Other Sources.

We also obtain information about you from other third party sources. We protect data obtained from these third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but may include:

  • Data brokers from which we purchase demographic data to supplement the data we collect.
  • Social networks when you reference our Service or grant permission to Company to access your data on one or more of these services.
  • Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly-available sources such as open government databases or other data in the public domain.

For further information on Third Party Services, see the section entitled “Third Parties” below.

  1. USE OF INFORMATION

We use information about you for our legitimate interests, including to:

  • Manage our Service, including your registration and account.
  • Perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service.
  • Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Prevent and address fraud, breach of policies or terms, and threats or harm.
  • Monitor and analyse trends, usage, and activities.
  • Improve the Service or other Company websites, apps, marketing efforts, products and services.

We also use information about you with your consent, including to:

  • Send you communications regarding our and third party products, offers, promotions, rewards, events, and services that may be of interest to you.
  • Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services.
  • Fulfill any other purpose disclosed to you and with your consent.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

  1. SHARING OF INFORMATION

We share information about you as follows:

  • Service Providers. We may share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing, data analytics, marketing and promotional services, Promotions, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
  • Affiliates. We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
  • Business Partners. We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a retailer for purposes of providing you with product support.
  • Third Parties. We may share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
  • Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
  • Consent.We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

  1. THIRD PARTIES
  • A. Third Party Services.

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

  • B. Third Party Features.

We may allow you to connect our Service to a Third Party Service or offer our Service through a Third Party Service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use. Some examples of Third Party Features include the following:

  • Sharing and Logging-In. We may embed a pixel or SDK on our Service that allows you to share content on, or log-in to your Company account through, Third Party Services, including social networks. If you choose to engage with such a Third Party Service through our Service, we may collect any information you have authorized the Third Party Service to share with us (such as your user ID, billing information, public profile information, e-mail address, birthday, friends list, and other account and profile data). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service may receive information about your activities on our Service and be able to associate that information with information the Third Party Service already has about you.
  • C. Analytics and Interest-Based Advertising.

Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics providers, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).

We may serve ads on Third Party Services, such as Facebook and Google, that are targeted to reach people (or similar people) on those services that have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by matching common factors between our data and the data of Third Party Services. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such Third Party Services’ failure to comply with your opt-out instructions.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

  1. YOUR RIGHTS AND CHOICES
  • A. Review and Update of Account Information.

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights as set forth in the section entitled “Your California Privacy Rights” below.

  • B. Tracking Technology Choices.
  • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.

  • C. Analytics and Interest-Based Advertising.

You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

  • D. Communications.

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or by contacting us as set forth in the section entitled “Contact Us” below. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Company’s ongoing business relations. Please note that your opt-out is limited to the e-mail used and will not affect subsequent subscriptions.

  • E. Your California Rights.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

Company may not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the description and include your name, street address, city, state, and ZIP code. Please note that Company is not required to respond to requests made by means other than through the provided e-mail address or mail address.

Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

  1. DATA SECURITY

We help protect your information from implement and maintain reasonable administrative, physical, and technical security safeguards against loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

  1. INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy.

  1. CONTACT US

If you have any questions or suggestions regarding our privacy policy, please contact us here.

IP Digital Marketing Privacy Policy

Interest Based Advertising and IP Targeting: We may work with data providers to serve advertising to
you through display media or other methods. These providers may use personal information that we
have collected or that you have provided to locate you online, such as when you visit or log in to
websites or mobile applications. This information may be linked to online identifiers or IP addresses
assigned to you, and to demographic or interest-based data, in order to target you with relevant
advertising, including about our products or services. To learn more about or opt out of this and other
interest-based advertising, please visit the industry opt-out pages operated by the DAA, at
http://www.aboutads.info and by the NAI at http://networkadvertising.org.