Effective Date: January 2, 2021
Advertising Specialty Institute, Inc. and its affiliates (referred to herein as “AS” or “we”) collect information about you when you use our website at www.asicentral.com and other websites, mobile application (the “ASI App”), or other online services that we operate (collectively, the “Services”).
If you have not done so already, please also review the Terms of Service.
2. INFORMATION WE COLLECT
- Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Such as name, signature, 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.
- Protected classification characteristics under California or federal law. - Age (40 years or older), religion or creed, sex (including gender, gender identity, gender expression, sexual orientation, veteran or military status.
- Commercial information. Information about your transactions with us, such as your account balances, investments and tax information and information we need to prepare a financial plan, such as your assets, liabilities, income and expenses.
- Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. Such as physical location or movements.
- Professional or employment-related information. Such as current or past job history or performance evaluations.
- Inferences drawn from other personal information. Such as a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may link together different types of Usage Information or link Usage Information to Personal Information. If linked information directly or indirectly identifies an individual person, then ASI treats the linked information as Personal Information.
- (a) Provide our Services to you: Most of time, the reason we process your information is to perform the contract that you have with us. For example, we use your information to maintain your account.
- (b) Legitimate interests: We use your information when we have legitimate interests in doing so. For example, we analyze users’ behavior to continuously improve Services and for administrative, fraud detection and legal purposes.
- (c) Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the information provided below.
3. HOW WE COLLECT INFORMATION
User Provided Information: We collect information that you provide directly to us, such as when you download and use the ASI App, create or modify your account, request customer support or otherwise communicate with us. This information includes (a) your name, postal address, email address and telephone number; (b) username, password and other registration information; (c) transaction-related information, such as when you download or use applications from us or register for the Services; (d) information you provide us when you contact us for help; and (e) other information you choose to provide and enter using the Services.
If you make payments through the Services we may also collect information required for payment processing, such as credit or payment card number, expiration date, cvv number, billing address, company name, and other information required for payment processing (“Payment Information”).
Automatically Collected Information: The Services automatically collect information about how you use the Services, such as (i) your mobile device or computer type, including your system and application software; (ii) the type of mobile device or computer you use, the pages and screens you view and how long you viewed them; (iii) your mobile device’s unique device ID; (iv) the IP address of your computer or mobile device; (v) your operating system, traffic data, logs and other communication data; and (vi) metadata and other information associated with other files stored on your device (e.g., photographs, audio and video clips and personal contacts). Some of this automatically collected information is Personal Information.
Information Collected from Third-Party Sources: We may combine information we receive from other sources with information we collect through the Services. For example, (A) if you engage with a third-party site application whose API we use (or who uses our API), we may receive information about you or your connections from such site or application; or (B) if you are referred to us by one of our referral partners, we receive information about you from such referral partner.
4. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (i.e., the internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Data Collection Technology helps us improve your experience of the Services by, for example, storing your password, measuring the success of marketing campaigns, compiling statistics related to use of the Services and helping us analyze technical and navigational information about the Services in order to detect and prevent fraud.
We may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, including the language your system uses and the country and time zone in which your computer or device is located.
We also use Google Analytics, which is a Google service that collects aggregate information about use of the Services and reports website trends. Google Analytics does not directly identify individual users. You can learn about Google’s practices and opt out by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
Your Control of Cookies: Some web browsers, including some mobile web browsers, provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
Do Not Track Signals: Some web browsers, including Safari, Internet Explorer, Firefox and Chrome, incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives such DNT signal, the browser can block that website from collecting certain Personal Information. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including ASI, do not respond to DNT signals.
5. HOW WE USE INFORMATION
We may use the information that we collect about you to (a) operate and provide you with the Services; (b) enhance and improve the Services (e.g., by identifying business partners who can provide supplementary services); (c) fulfill any other purpose for which you provide your information; (d) carry out ASI obligations and enforce ASI rights arising under any agreement between ASI and you; (e) notify you when updates to the Services are available; (f) send or facilitate communications between you and other users (e.g., between a driver and fleet operator in connection with your use of certain features of the Services); (g) determine how the Services are used, analyze trends and improve the Services; and (h) to secure and protect the Services and prevent and investigate fraud and other misuses of the Services.
6. HOW WE SHARE INFORMATION
ASI shares your Personal Information as requested by you (e.g., to process payments), for any purpose disclosed by ASI when you provide such information, to fulfill the purpose for which you provide such information, and in order to provide the Services for which you signed up.
ASI may share your information (a) with ASI affiliates and business partners who help us provide, analyze and improve the Services; (b) with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ASI assets; (c) to comply with any court order, law or legal process, including to respond to any governmental or regulatory request; (d) to carry out ASI obligations and enforce ASI rights arising under any agreement between ASI and you; and (e) if ASI believes disclosure is necessary to protect the rights, property or safety of ASI, our customers or others. Additionally, we may share your information with companies that are conducting marketing and advertising to benefit ASI. These third party companies may use your contact information for communications and marketing purposes that support our activities. You are under no obligation to respond and the companies are restricted from using your contact information for any other purpose.
ASI may disclose Usage Information without restriction.
7. YOUR CHOICES ABOUT INFORMATION
You can stop all collection of information by the ASI App by uninstalling it. You may use the standard uninstall processes available as part of your mobile device. You can stop collection of information by of the Services by ceasing to use such Services.
If you would like to review, correct, update or delete Personal Information that you have previously provided to us or if you would like to suppress, restrict or receive an electronic copy of your Personal Information (if these rights are provided to you by applicable law), please contact us via email at email@example.com.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database and any other limitations you would like to put on our use of your Personal Information. For your protection, we only fulfill requests when received from the email address associated with your account. We may need to verify your identity before fulfilling your request.
Please note that we often need to retain certain information for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. We also may not allow you to review certain data for legal, security or other reasons.
- (a) the length of time we have an ongoing relationship with you and provide Services to you (e.g., for as long as you have an account with us or keep using the Services);
- (b) whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
- (c) whether retention is advisable considering our legal position (e.g., for statutes of limitations, litigation or regulatory investigations).
Notice to California Residents: California Civil Code Section 1798.83 permits individual 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 contact us at firstname.lastname@example.org. Please note, however, that ASI does not disclose Personal Information to third parties for their direct marketing purposes.
8. SECURITY OF YOUR INFORMATION
We are concerned about safeguarding your information. We use physical, technical, and organizational safeguards intended to protect information that we process and maintain. Unfortunately, however, no system or online transmission of information is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.
You are responsible for maintaining the security of any password or other form of authentication involved in obtaining access to password-protected or secure areas of the Services. Access to the Services through your credentials will be treated as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.
If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
9. LINKS TO OTHER WEBSITES AND SERVICES
11. CHILDREN’S PRIVACY
The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.
12. CALIFORNIA RESIDENTS
Information We Collect
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Services collect or may have collected the following categories of personal information in the last twelve (12) months. We obtain the categories of personal information as described in the “Information We Collect” section above.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the business purposes indicated in the “How We Use Information” section above.
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 categories of third parties listed in the “How We Share Personal Data” section above.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- California Customer Records personal information categories
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Professional or employment-related information
- Inferences drawn from other 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.
Right to Access Specific Information and Data Portability Right
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 twelve (12) months. Once we receive and confirm your verifiable consumer request, 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 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 disclosed your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Delete
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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at: 800-546-1350, press 1 at the greeting
- Mailing us at: Advertising Specialty Institute. Inc.
4800 East Street Road
Trevose, PA 19053
For submissions via email, please complete and send us a completed copy of this Verifiable Consumer Request Form.
Only you, or a person registered with the California Secretary of State that you authorize 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 such a 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, and 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.
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. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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.
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.
We will not discriminate against you for exercising any of your CCPA rights.
13. NOTICE TO INTERNATIONAL VISITORS
14. EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS
ASI participates in the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks. Please see our Privacy Shield Policy for information about ASI data practices regarding personal information it receives from European Union member countries and Switzerland pursuant to the respective Privacy Shield frameworks. To learn more about the Privacy Shield program generally, and to view our certification, please visit https://www.privacyshield.gov/. In the event Privacy Shield is no longer deemed adequate by the European Commission, ASI will continue to comply with its requirements under the Privacy Shield framework, and otherwise take steps to comply with the General Data Protection Regulation.
15. CONTACT US
If you have any questions regarding privacy while using the Services or have questions about our practices, please contact us via email at email@example.com.