PRIVACY POLICY

Effective Date: December 10, 2019

MacDuff Enterprises, Inc. dba 729 Solutions (the “Company”) takes privacy matters seriously and wants you to be familiar with how we collect, use, and disclose data. The Company provides this Privacy Policy to explain our practices regarding the collection, use, disclosure, and protection of personal information that apply to our website at https://729solutions.com/, including, without limitation, our mobile websites, mobile applications, social networking or other interactive media sites, other online or mobile services, and any other platforms that link to this Privacy Policy (collectively, the “Site”), as well as your choices regarding the collection and use of your information. This Privacy Policy does not apply to information we collect by means (including offline) or from other sources other than through the Site.

As part of our commitment, we strive to protect the privacy of visitors to the Site. You can navigate the majority of the Site without giving us any personal information which identifies you. However, sometimes we need additional information about you in order to provide you with information or services you want to receive from us.

In this digital world, privacy is important to the Company and should be important to you. The Company believes in transparency and we provide this notice so that you can understand our online information practices and the choices you can make about the way your information is collected and used.

The Information We Collect and Process

The Company collects and processes two basic types of information:

Personally identifiable information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information) (“Personally Identifiable Information”). This information is voluntarily provided to us by Site visitors and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services. The Company only collects Personally Identifiable Information that you voluntarily provide, for example, when you use our “Contact Us” feature. Under such circumstances you consent to our use/processing of the information you provide consistent with this policy.

Non-Personally Identifiable Information: We also collect and use information about your interactions with the Site in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information”). This information gives us insights on how Site visitors use our site. This data is anonymous and does not contain any personally identifiable information. We use this information to ensure that our website, e-mails and marketing efforts continue to appeal to Site visitors and clients. Generally, we do not combine or associate Non-Personally Identifiable Information with your Personally Identifiable Information. If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, we treat the combined information as Personally Identifiable Information. We may collect, use, and disclose Non-Personally Identifiable Information as set forth below.

The Way We Use Information

We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with the Company employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.

For example, if you provide your name, mailing address, telephone and/or email address and request more information about the Company’s services, this information will be shared with appropriate Company personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.

We use non-identifying and aggregate information about the use of the Site to improve the navigation, content, and design of the Site. This information may include, for example, the most and least requested pages, analyzing traffic regarding specific features, and the number of users from the U.S. and other countries, among other things.

The Company will not sell or distribute personally identifiable information collected from you outside of the Company without your consent (subject to the limited exceptions stated in this policy).

How Information May be Shared or Disclosed

The Company may preserve and has the right to disclose any information about you or your use of the Site without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of the Company or its clients or their respective partners, employees, affiliates, other users of the Site, or the public; or (b) respond to claims related to your use of the Site. We may also disclose information as required by law or subpoena to satisfy any applicable law, regulation, legal process or lawful governmental request (including to meet national security or law enforcement requirements) or in the event of a sale or potential sale, merger, acquisition, bankruptcy, or dissolution of the Company or one of its business units or similar transactions or proceedings.

Google Analytics

The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the Site analyze how users use the Site.

The Company uses Google Analytics features including:

    • Remarketing with Google Analytics
    • Google Display Network Impression Reporting
    • DoubleClick Platform integrations
    • Google Analytics Demographics and Interest Reporting

The Company uses all features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keyword used to visit this website. Google Analytics does not store any visitor specific data and we will not use visitor specific data in any way related to Google Analytics, Google AdWords, and Remarketing.

The Company and other third-party vendors, including Google, use first-party cookies such as the Google Analytics cookie and third-party cookies such as the DoubleClick cookie together to inform, optimize, and serve ads based on visitor’s past visits to our website.

The Company uses remarketing with Google AdWords (see below) and analytics to display content specific advertisements to visitors that have previously visited our site when those visitors go to other websites that have the Google Display Network implemented.

The information generated by the cookie about your use of the website including your IP address will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however if you do this you may not be able to use the full functionality of the Site. By using this Site, you agree to the processing of data about you by Google in the manner and for the purposes explained in this paragraph.

We use Google AdWords remarketing services to advertise on third party websites (including Google) to previous visitors to our Site. Remarketing allows us to tailor our outreach to better suit your needs and only displays ads that are relevant to you. AdWords remarketing may appear in the form of an advertisement on the Google search results page, or a site in the Google Display Network, or display relevant ads tailored to your interests based on what parts of the Company’s Site you have viewed or by placing a cookie on your machine. This cookie does not in any way identify you or give access to your computer. Any data collected will be used in accordance with our Privacy Policy.

What is ReTargeting?

The main goal of ReTargeting Ads is to re-engage site visitors after they have left a site. Dynamic ReTargeting Ads are generated based on the actual products or offers viewed on the advertiser’s site. For example, if you’ve visited a retailer’s website and viewed a specific product, you might receive a banner ad containing that product. Rather than showing the same ad to every visitor, the site’s Dynamic Ad Application will select the most relevant ad copy based on the user’s activity on the site. The Site’s Personalized Retargeting Platform works when an advertiser places our tag on his website. The tag embeds a third party cookie on the browser of users visiting the Site. Using Real Time Bidding (RTB) Ad Exchanges, it is then possible to focus media buying efforts against those visitors. It is important to note that the cookie itself does not contain any personal identifying information. Our Personalized ReTargeting ads intelligently match the right offering to each visitor based on such visitor’s previous activities on the Site. Each advertiser using the Company’s service is responsible to limit the number of ad impressions shown to each user in order to ensure that viewers are not overly exposed to specific ads.

How can I remove myself from being ReTargeted?

The Site makes removing our tracking cookie easy for any user who wishes to do so. Users that don’t want to see the Company’s Personalized Ads should simply email us at privacy@729solutions.com .

Data Security

The Company understands that the safety of your personal information is extremely important to you. Accordingly, the Company uses reasonable technological, physical and other measures to keep your information protected from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of any information, including your Personally Identifiable Information, and the Company expressly disclaims any such obligation.

Retention Period

We will retain information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Children’s Privacy

The Company understands the need to protect the privacy of children. The Site is directed to adults who are at least 18 years old and is not intended for use by individuals under 18 years of age. When a user discloses personal information on this Site, the user is representing that he or she is an adult. The Company does not knowingly collect or maintain personal information from children under the age of 18 at our Site. If we obtain knowledge that a child under the age of eighteen has provided us with personally identifiable information, we will promptly delete such information. If you are a parent or guardian and discover that your child has provided any such Personally Identifiable Information to us, then you may contact us at the email or mailing address noted at the end of this Privacy Policy below and request that we delete that information from our systems.

How You Can Access or Correct Your Information

You may access, update or remove the information you provided to us by contacting us – see “How to Contact Us” below. Similarly, Site users who wish to subscribe or unsubscribe to our marketing and informational communications or limit our use of any Personally Identifiable Information in any way can do so by using the subscribe/unsubscribe options contained in our emails or by sending an email to privacy@729solutions.com. Upon receiving your email with the request to update or remove your information, our privacy team will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. Some information may be retained for longer periods as required by law, contract or auditing requirements.

Links to Other Websites

Our Site contains links to other websites. The Company is not responsible for any websites that it does not own or operate. You should carefully review the privacy policies and practices of other websites that you link to from the Site, as we cannot control or be responsible for their privacy practices.

International Users

Information provided through this Site may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Site, you consent to the transfer, processing and/or use of the information globally throughout the Company. Wherever the information is transferred or accessed within the Company it will be processed and used in accordance with this privacy policy.

Your Rights If You Are a Resident of the European Union or United Kingdom

Subject to applicable data protection laws, customers and users have the following rights with respect to the Company’s handling of Personally Identifiable Information for which the Company is the data controller:

  • Access. The right to request access to Personally Identifiable Information held by the Company.

  • Objection. The right to object to certain processing of Personally Identifiable Information (unless the Company has overriding compelling grounds to continue processing), including the right to opt-out of receiving direct marketing. We will, however, continue to use Personally Identifiable Information for the limited purpose of communicating important notices relating to changes to the Service or policies, and other reasons permitted by law.

  • Rectification. The right to request correction of Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated.

  • Right to be Forgotten. The right to request erasure of all Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. The Company will do everything possible to erase Personally Identifiable Information if a user or customer so requests. However, the Company will not be able to erase all Personally Identifiable Information if it is technically impossible due to limitations of existing technology or for legal reasons, such as Fauna is mandated by applicable law to retain Personally Identifiable Information.

  • Restriction of Processing. The right to request restriction of processing Personally Identifiable Information for certain reasons, such as the inaccuracy of Personally Identifiable Information.

  • Data Portability. If requested, the Company will provide Personally Identifiable Information in a structured, secure, commonly used and machine-readable format.

  • Right to Withdraw Consent. If Personally Identifiable Information is processed solely based on consent, and not based on any other legal basis, customers can withdraw consent at any time.

  • Data Protection Contact. The right to contact the relevant data protection regulator regarding the Company’s handling of Personally Identifiable Information.

To exercise any of the above listed rights, email the Company at privacy@729solutions.com, or mail 729 Solutions, 388 MARKET STREET, SUITE 1300, SAN FRANCISCO, CA 94111, Attn: Privacy. The Company will process requests in accordance with applicable law, with reasonable efforts and within a reasonable period of time.

Notification of Changes

As we provide more services and/or functionality on our Site and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. We will put an “Updated” note on the link to the Privacy Policy on the Site’s home page so that you will be able to check regarding changes which may be of particular relevance to you.

Do Not Track

At this time, our Site does not support “Do Not Track” preferences that may be available in your browser for letting websites know that you do not want them collecting certain kinds of information. If you turn on the “Do Not Track” setting on your browser, our Site is not currently capable of following whatever Do Not Track preferences you set. For more information about Do Not Track, visit www.donottrack.us.

California Privacy Rights

Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents who provide Personally Identifiable Information in obtaining products and services for personal, family or household use are entitled to request and obtain from the Company, once per calendar year, information about Personally Identifiable Information the Company has shared, if any, with other businesses for their own direct marketing uses. The Company does not currently share your Personally Identifiable Information with other businesses for their own direct marketing uses. However, if applicable, this information would include the categories of Personally Identifiable Information and the names and addresses of those businesses with which the Company shared Personally Identifiable Information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information, please send an email to privacy@729solutions.com with “Request for California Privacy Information” in the subject line, or via mail to: 729 Solutions, 388 MARKET STREET, SUITE 1300, SAN FRANCISCO, CA 94111, Attn: Privacy.

How to Contact Us

If you ever have any questions about this Privacy Policy, please contact us at privacy@729solutions.com or via mail at: 729 Solutions, 388 MARKET STREET, SUITE 1300, SAN FRANCISCO, CA 94111, Attn: Privacy.