Privacy Policy

Pingtree LLC (“Pingtree”, “we”, “us”, “our”) provides web-based advertising network, affiliate tracking, targeting, reporting and analytics services (“Platform Services”), that are facilitated by Pingtree’s cloud platform (“Platform”), to our customers (“Pingtree Customers”). This Statement of Privacy applies to www.pingtree.com (“Website”), and Pingtree LLC and governs data collection and usage. This Privacy Policy explains how Pingtree processes (i) data from Pingtree Customers’ end users (“End Users”) on behalf of Pingtree Customers; and (2) Website Visitor Information (as defined herein).

The Pingtree website is a marketing and analytics platform site. Pingtree Customers determine the data that they provide to and collect through Pingtree; their use, collection, exportation, or any other use of End User data is subject to their respective privacy policies and applicable laws, and regulations. By using the Pingtree website, you consent to the data practices described in this statement.

Throughout this Privacy Policy, when we use the words “you”, “your”, or “user”, we mean an individual End User of a Pingtree Customer viewing ads displayed using the Platform Services. Pingtree Website visitors are referred to as “Visitors”.

Pingtree Customers and End Users

This Privacy Policy does not address the practices or policies of Pingtree Customers, nor of any website, mobile app, or other property on which ads are displayed using the Platform Services. Pingtree is solely a technology and tools provider and does not engage in brokering, displaying or executing any ad campaign. Pingtree Customers use the Platform Services and collect and process End User personal information and data, including Collected Information (as defined herein), for the purpose of marketing to individuals (“Personal Data”). For clarification, Personal Data includes Collected Information and Visitor Information (as defined herein).

Pingtree Customers own the Personal Data that they provide to and collect through the Platform Services. The collection, retention, processing and other uses of data by Pingtree Customers, whether or not in connection with the Platform Services, is governed by their own privacy policies and applicable laws, rules, or regulations. Pingtree does not control those Pingtree Customer activities.

Data Protection Laws

Each Pingtree Customer is the data controller with respect to Personal Data. Under the applicable laws of various countries, you may have certain rights concerning your Personal Data, such as under EU law, the right to access to, rectification or erasure of, and/or restriction of processing or objection to processing of your Personal Data. If you believe that a Pingtree Customer has collected or processed your Personal Data, and you have any questions or want to exercise any of your rights with respect to your Personal Data, you should contact them directly.

Pingtree operates as a “data processor” under the General Data Protection Regulation (“GDPR”) and as a “service provider” under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 ("CPRA"). Pingtree adheres to these data protection laws. Accordingly, we generally do not have the authority to provide access to or deletion of your Personal Data; you will have to contact the relevant Pingtree Customer.

Collection of Personal Information

In order to better provide you with products and services offered, Pingtree may collect personally identifiable information, such as your:

• First and Last Name
• Mailing Address
• E-mail Address
• Phone Number

Pingtree requires personnel contact details to set up a Pingtree Customer account – including mailing and/or billing address, email address, company name, and website URL. Pingtree Customers also need to provide a username and password. If you purchase Pingtree's products and services, we collect billing and credit card information. This information is used to complete the purchase transaction. All of this information is handled according to the service agreement between Pingtree and the Pingtree Customer.

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: (a) registering for an account; (b) signing up for special offers from selected third parties; (c) sending us an email message; (d) submitting your credit card or other payment information when ordering and purchasing products and services. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

The Pingtree Platform Services allow Pingtree Customers to collect various kinds of information about their End Users (“Collected Information”).

Pingtree Customers can use the Platform Services to create “cookies” (small text files that are saved by your browser) and “pixel tags” or “web beacons” (one-pixel graphic files which are delivered from the Platform Services web server) that can be placed in advertisements or on websites or other apps to collect information about user interaction with the advertisements or websites. Pingtree also supports server-to-server measurement for some Pingtree Customers. With any of the mentioned methods, when an End User views or clicks on an advertisement, goes to a specific web page, or takes any other action that a Pingtree Customer chooses to monitor, the Pingtree Platform Services collect information from the End User’s computer or device, as described below.

Log Data. The Platform Services automatically record certain information (“Log Data”) when an advertisement is displayed to an End User through the Platform Services, or when an End User views a web page with a cookie or pixel tag created with the Platform Services. Log Data may include information such as an End User’s Internet Protocol (IP) address and network status, mobile device identifier, application identifier, browser type, operating system, the pages or page features which an End User browsed and the time spent on those pages or features, frequency with which the Platform Services encounter the same End User, search terms, the links or advertisements on which an End User clicked, and other statistics.

Advertising Identifiers. As part of the Log Data, the Platform Services may collect advertising identifiers, which are resettable identifiers unique to your mobile device, and which are used in connection with advertising delivered to your mobile device. Examples of advertising identifiers include IDFA (developed by Apple for the iPhone) and Google Ad ID (developed by Google for Android). If you don’t want advertising identifiers to be used to provide targeted advertising to you, see the section below titled “Opting Out of Targeted Advertising”

Location Information. The Platform Services may collect and store information about where you are located, both by collecting precise geolocation information from your mobile device if and as permitted by you, and by converting your IP address into a rough geolocation and utilizing your mobile phone number to approximate rough geolocation information (based on area code).

California Resident Rights

If you are a California resident, you have the rights outlined in this section. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict.

To the extent applicable and provided for by law, California residents have the following privacy rights in relation to the Personal Data we collect:

• The right to know: End Users and Visitors have the right to know what personal information we have collected and how we have used and disclosed that Personal Data;
• The right to delete: End Users and Visitors have the right to request deletion of their Personal Data;
• The right to non-discrimination: End Users and Visitors have the right be free from discrimination relating to the exercise of any of their privacy rights.

Exercising Your Rights: California residents can exercise the above privacy rights or request to receive this notice in a different format by emailing us at: accounts@pingtree.com.

Verification: in order to protect Personal Data from unauthorized access or deletion, we may require End Users and Visitors to verify their identification before they can submit a request to know or delete Personal Data. If we suspect fraudulent or malicious activity, we may ask for additional Personal Data for verification. If we cannot verify their identity, we will not provide or delete their Personal Data.

Authorized Agents: End Users and Visitors have the right to designate an authorized agent to make requests to us to exercise any rights under the CCPA or CPRA.

Use of your Personal Information

Pingtree collects and uses your personal information to operate and deliver the services you have requested.

Pingtree may also use your personally identifiable information to inform you of other products or services available from Pingtree and its affiliates.

Pingtree Customers use information according to their own privacy policies and applicable laws and regulations. However, Pingtree provides the following types of data analysis functionality within the Pingtree Platform Services for use by Pingtree Customers and only as directed by Pingtree Customers:

• Measuring the performance of advertising campaigns (including fraudulent activity);
• Identifying possible relationships among different browsers and devices;
• Limiting the number of times a specific advertisement is presented to the same browser or mobile device (frequency capping);
• Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region or among a particular demographic); and
• Improving the targeting or relevance of advertising to users.

We use the information collected through the Platform Services to provide, improve, and promote the Platform Services; uses include the following:

• To provide the Platform Services to and for the Pingtree Customer on behalf of which the Platform Services collected the information, as described in this Privacy Policy; and
• To monitor, research, analyze and report on the usage of the Platform Services, solely on an aggregate, non-identifiable basis.

Data Retain

Each Pingtree Customer sets the Personal Data retention period. If you have questions or want more details, please contact the relevant Pingtree Customer. Pingtree retains Personal Data that it processes on behalf of each Pingtree Customer for as long as needed to provide Platform Services as directed by that Pingtree Customer. Pingtree will also retain Personal Data as necessary or legal purposes (for example, to comply with its legal obligations, resolve disputes, and enforce its agreements).

Opting Out of Targeted Advertising

Pingtree Customers may use the Platform Services to provide ads that are likely to be interesting and relevant to End Users (“Targeted Advertising”). One way Pingtree Customers may do this is by gathering Collected Information related to End Users, which may include elements like mobile websites you have visited or mobile apps that you use, preferences that you may have provided to your app provider or to the Pingtree Customer, information collected by third parties or Pingtree and shared with the Pingtree Customers, advertising identifiers, or location information (e.g., GPS or Wi-Fi data if you have enabled those services). Pingtree Customers may also link an identifier to additional information from other partners to provide the Pingtree Customer with information about users’ likely interests.

If you or a Visitor wishes to "opt out" of Targeted Advertising based on the types of techniques described above, your options include the following:

• Reset your mobile device’s advertising identifier or set it to opt out of targeted advertising.
• Android: You can reset your advertising ID at any time, right from the Ads section of the Google Settings app on your device. From the same app, you can also opt-out of targeted advertising based on the advertising ID by setting the appropriate ad tracking preference.
• iOS: You can opt out of targeted advertising by accessing the following link on your device: http://oo.apple.com. Alternatively, if you are using the iOS 6 or above operating system on your device, you may opt-out by electing Limit Ad Tracking in your device’s settings menu (as of the date of this Privacy Policy, located at Settings > Privacy > Advertising).

You should be aware that if you or a Visitor “opts out” it does not mean that you or Visitor will no longer receive advertising. It just means that the advertising you or Visitor sees displayed will not be customized and may be less relevant.

Sharing Information with Third Parties

Pingtree does not sell, rent or lease its customer's data to third parties.

Pingtree may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Pingtree, and they are required to maintain the confidentiality of your information.

Pingtree may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Pingtree or the site; (b) protect and defend the rights or property of Pingtree; and/or (c) act under exigent circumstances to protect the personal safety of users of Pingtree, or the public.

Service Providers. We may engage third party service providers to work with us to administer and provide the Platform Services. These third party service providers have access to Personal Data only for the purpose of performing services on our behalf.

Third Parties. We may share aggregated, non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes.

In Connection with Business Transactions. Personal Data is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, Personal Data may be disclosed or transferred to the third-party acquirer in connection with the transaction.

For Our Protection and the Protection of Others. It is our policy to protect you and Visitors from privacy violations from abuse of the legal systems, whether by individuals, entities or government, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you or Visitors to government or law enforcement officials or private parties in order to: (a) satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders; (b) enforce our agreements with you or third parties, to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and (c) prevent or stop activity we consider to be illegal or unethical.

Information Security We take commercially reasonable measures to protect Personal Data from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Tracking User Behavior Pingtree may keep track of the websites and pages our users visit within Pingtree, in order to determine what Pingtree services are the most popular. This data is used to deliver customized content and advertising within Pingtree to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information Information about your computer hardware and software may be automatically collected by Pingtree. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Pingtree website.

When a Visitor visits the Website, Pingtree collects information about his/her device and use of the Website to improve the Website (“Visitor Information”). Pingtree also collects any Visitor Information a Visitor voluntarily provides when he/she visits the Website. The type of Visitor Information Pingtree collects from a Visitor will depend on his/her request or interaction with the Website. Types of Visitor Information Pingtree collects from a Visitor may include specific times of day he/she accesses the Website, the IP address of the device a Visitor used to access the Website, the pages on the Website that a Visitor viewed, the pages a Visitor visited before navigating to the Website, and information about the device a Visitor uses to access the Website, including hardware model, operating system and version, and browser.

Pingtree uses Visitor Information collected on the Website for various purposes, including:

• Ensuring its Website remains relevant to end user needs and are easy to use by providing analytics and other data regarding use of our Website
• Sending marketing and promotional communications in compliance with applicable laws
• Enhancing, improving, or modifying its Website and services, enhancing security, or combating spam or malware or other security risks
• Providing confirmations, invoices, technical notices, updates, security alerts, and other support and administrative messages
• Providing Targeted Advertising

Use of Cookies

The Pingtree website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Pingtree pages, or register with Pingtree site or services, a cookie helps Pingtree to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Pingtree website, the information you previously provided can be retrieved, so you can easily use the Pingtree features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Pingtree services or websites you visit.

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Security of your Personal Information

Pingtree secures your personal information from unauthorized access, use, or disclosure. Pingtree uses the following methods for this purpose.

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Children Under Eighteen

Pingtree does not knowingly collect personally identifiable information from children under the age of eighteen. If you are under the age of eighteen, you must ask your parent or guardian for permission to use this website.

Disconnecting your Pingtree Account from Third Party Websites

You will be able to connect your Pingtree account to third party accounts. BY CONNECTING YOUR PINGTREE ACCOUNT TO YOUR THIRD PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third party account at any time.

E-mail Communications

From time to time, Pingtree may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Pingtree or click on a link therein. If you would like to stop receiving marketing or promotional communications via email from Pingtree, you may opt out of such communications

Changes to this Statement

Pingtree reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our website, and/or by updating any privacy information. Your continued use of the website and/or Services available after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

Pingtree welcomes your questions or comments regarding this Statement of Privacy. If you believe that Pingtree has not adhered to this Statement, please contact Pingtree at:

Pingtree LLC
1637 East Valley Parkway #237
Escondido, California 92027

Email Address
Accounts@pingtree.com

Effective Date
Effective as of June 13, 2023