PRIVACY POLICY

 

Inuvo®, Inc. and its subsidiaries (“Inuvo” or “we”) takes consumer privacy seriously. We are committed to following industry standards, best practices and guidelines relating to the use of consumer information and privacy.

This privacy policy is intended to inform consumers about the way we use and protect the information we collect about customers and users. Information is collected by us through (i)  our website www.inuvo.com, through other Inuvo owned and operated websites (and all websites and URLs controlled or operated by Inuvo or our subsidiaries that link to this policy) (collectively, the “Websites”), and (ii) our IntentKey technology platform (“IntentKey”) and our ValidClick marketing and advertising service (“ValidClick” collectively, IntentKey and ValidClick may be hereinafter referred to as our “Advertising Technology Products”) .  This privacy policy is intended for both website publisher customers (“Publishers”), advertising customers (“Advertisers”) and individual users of our Websites and apps.

• For Publishers, this privacy policy explains how we may collect, use and disclose information associated with your company and with your company’s websites and apps that use our ValidClick service.
• For Advertisers, this privacy policy explains how we may collect, use and disclose information associated with your company and its advertisements for use on our Websites, and our Advertising Technology Products.
• For individual Website and app users, this privacy policy explains how we may collect, use and disclose information when you visit our Website(s) or when you use any Website or app that uses our Advertising Technology Products.

Publishers that utilize our Advertising Technology Products may also have their own policies that govern how they collect, use and share data.  These policies may differ from our policies described in this privacy policy.

INFORMATION COLLECTION AND USE

We collect information when you choose to share it with us on our Websites, such as signing up for newsletters or opting in to receive information from us. For example, you may choose to send us information about yourself in an email or by completing an online form on one of our Websites or to utilize our services as a Publisher or an Advertiser. We use this information to contact you to respond to an inquiry, and in some instances, certain parts of our Websites require requested information for you to participate in programs and services. We also collect information when you sign up as an Account Holder. Account Holders include both Advertisers and Publishers who have been qualified and approved for access to our Advertising Technology Products. Account Holder information collected includes information necessary to conduct business including, but not limited to, account holder name, phone number, email address, and/or tax ID number. Payments made to and/or from Inuvo require the provision of and specified collection of additional information which may include, but is not limited to, bank account information and credit card numbers. Phone, facsimile, email and/or cell numbers may be used to contact Account Holders as needed.

All Account Holder information collected is maintained in a password-protected environment. This information is used for client/customer service, media delivery, contact, billing-payables and receivables and/or other reporting purposes. Account Holders may change, update or add additional information about themselves by contacting their account representative.

We also collect additional information via our Websites and our Advertising Technology Products, such as the following:

• Cookies. We use “cookies.”  The cookies we place on your computer are very small text files that uniquely identify your browser and may be sent to your computer or mobile device.  They are stored on your hard drive and communicate to our servers only when you are visiting our Websites or a Publisher website utilizing one of our Advertising Technology Products.  You are always free to decline cookies. You can configure your browser to accept all cookies, reject all cookies, erase cookies or notify you when a cookie is set. For more information about cookies and web beacons, visit http://www.allaboutcookies.org/cookies/.
• Device Information. We collect information regarding the Internet browser, computer, tablet, mobile phone, smartphone or other device utilized to access our Websites or Advertising Technology Products.
• Internet Protocol Addresses. Internet browsers automatically transmit information such as the URL of the Website you just came from and the Internet Protocol (IP) address and the browser version of your computer.
• Location Information. On some of our mobile applications we may (or may enable a third party to) request your geolocation information.  If allowed, we (or the third party) may use this information to supply you with location specific advertisements, offers and functionality.  Additionally, we may (or may enable a third party to) capture geolocation information (such as IP address data) when you access our Websites or via our Advertising Technology Products, and may use that geo-location information to targets ads, offers and functionality.
• Analytics. We use third party information, reports and analysis about the usage and browsing patterns of Internet users.  We allow the third party analytics companies to include web beacons and cookies on certain of our Websites and in some of our Advertising Technology Products. The collected information includes search terms, search parameters, click-throughs by users, and other similar information.
• Log Files. We may also automatically log certain anonymous information about visitors to our Websites, including, but not limited to, where the user came from to visit our site, IP address, search terms utilized, browser type and a reading history of the pages viewed.
• Web Beacons. We (or our third party partners) may use web beacons.  Web beacons communicate information from your Internet browser to a web server.
• Other. As new technologies develop we may implement and/or test them on our Websites or in our Advertising Technology.  We only utilize technologies as permitted by law.

We use information we collect via our Websites for five basic purposes.

1. The first is to improve and customize the content and advertisements on our Websites, this includes items such as ensuring our sites and content are viewable and in the appropriate language.
2. The second is to “frequency cap” ad campaigns that we administer. Frequency capping controls the number of times you are exposed to an ad, which results in a better experience for you and the advertiser.
3. The third is to serve appropriate promotions from advertisers if you have expressed an implied interest by visiting that advertiser’s site (known as “retargeting”).
4. The fourth way is for Interest-Based Advertising (IBA), which uses consumer data to infer intent. We retain this data for 60 days, after which the data is aggregated and maintained for an additional two years solely for reporting purposes.
5. The fifth way is for business purposes, such as data analysis, audits, record keeping, and contractual compliance.  While we also use information in a limited fashion for the administration and operation of our Websites, it is used primarily to improve the overall quality of experience with the information we provide on our Websites.

PUBLIC FORUMS

Some of our Websites make chat rooms, polls, surveys, forums, message boards, blogs commentary and/or news groups available to users. Please remember that any information that is disclosed in these areas becomes public information. You should exercise caution when deciding to disclose your information through these channels.

THIRD-PARTY WEBSITES AND ADVERTISEMENTS

Our Websites may contain links to other websites, including Advertiser offers. Third parties may perform functions on our behalf, such as fulfilling orders, providing promotional materials to our users, sending email, managing data, processing credit card payments or providing customer service. They have access to your Personal Information (as defined below) only to the extent necessary to perform their functions and may not use it for any other purpose.

Such websites may use cookies and/or other data collection tools. We are not responsible for the privacy practices, policies or content of such other websites. We encourage everyone to read the posted privacy policies whenever interacting with any website to learn more about the privacy practices of that website. We have no control over the use of information by third-party websites, and you should exercise caution when deciding to disclose any information to those websites.

Sometimes we use third-party advertising companies to serve ads when you visit our Websites. These companies may use information about your visits to our and other websites in an effort to provide advertisements about goods and services that may be of interest to you. To learn more about third-party advertising, interest based advertising, or to opt-out of such advertising, you can visit both the Network Advertising Initiative and the Digital Advertising Alliance.

 

In addition to the above, on some of our Websites we have implemented certain “Google Analytics” features that support display advertising, including re-targeting. Visitors to these websites may opt out of Google Analytics, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

 

INFORMATION SHARING

We share your information as follows:

Service Providers

We engage third party companies and individuals to perform services on our behalf (e.g., software maintenance services, advertising serving technologies, e-mail service providers, delivery services, database management, web analytics, payment processing and other services). These third parties have access to your information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your information for any purpose other than to provide this assistance, except to the extent required by law. We may permit our service providers to use aggregate information which does not identify you or de-identified data for other purposes.

Affiliates

We share your information with our affiliates for internal business purposes, including for customer support, marketing, and technical operations.

Third Parties

We may share your information with third parties in connection with tailoring advertisements, measuring and improving our service offerings and advertising effectiveness, and enabling other enhancements.

Compliance with Laws, Legal Process and Authorities

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We must disclose your information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. We may also disclose information to protect the rights, property, life, health, security and safety of us, the Service or any third party.

Business Transfers

Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Consent and Disclosure

We may share your information for purposes disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share 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.

INFORMATION SECURITY AND STORAGE

All information collected via information request forms or contact us emails is only used to respond to that inquiry. Once collected, we will store your information for a reasonable time for record-keeping purposes and promotional marketing efforts.

All Account Holder information collected is maintained in a password-protected environment. This information is used for client/customer service, media delivery, contact, billing-payables and receivables and/or other reporting purposes.

We retain information for use to more effectively match advertisements and website content to your interests for up to 60 days from the users last interaction with our Advertising Technology Products and for data analysis, audits, record keeping, and contractual compliance purposes for up to two years.  This data includes, but is not limited to, IP address, content viewed, ad interaction, interaction with other advertiser websites, browser type, Internet Service Provider, the time/date of the visit to our Websites, the computer’s operating system (e.g., Windows XP), search terms used and other click and browsing behavior.

SECURITY

We use industry standard practices to safeguard the confidentiality of information and treats data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company.

COMPLIANCE WITH THE NETWORK ADVERTISING INITIATIVE

Inuvo is a member of the Network Advertising Initiative (NAI) and follows the NAI’s Code of Conduct.  Inuvo will sometimes use third-party data providers to complement its product offerings, and some of these companies are also fellow members of the NAI. For more information on the NAI, or to opt out of behavioral targeting delivered by NAI member companies, please visit www.networkadvertising.org.

Inuvo does not engage in retargeting campaigns that market prescription drugs. However, Inuvo may offer retargeting services for consumer health products that do not require a prescription. Examples of where retargeting might be offered include certain health categories such as fitness equipment, calorie counters, etc.

TRUSTe

Inuvo is a licensee of the TRUSTe Ads Program. TRUSTe is an independent organization with the mission to build a user’s trust and confidence in the Internet by promoting the use of fair information practices.

If you have any questions or concerns regarding this statement, you should first contact Inuvo using the contact information provided at the bottom of this page. If you do not receive acknowledgment of your inquiry or your inquiry has not been addressed to your satisfaction, please contact TRUSTe by visiting the following site: https://feedback-form.truste.com/watchdog/request. TRUSTe will function as a liaison with Inuvo to help resolve your concerns.

 

YOUR RIGHTS AND CHOICES

Opt-Out Or Update Your Information

As an Account Holder, you will only receive email communications from us for business administration purposes, including Website and platform service updates. Any promotional emails you may receive will have an opt-out option within the footer of the email. If you opt-out, you will be removed from the promotional email list, however, as an Account Holder, you will still receive any/all business administration emails applicable to your account. As an Account Holder, you can update your information by contacting your account representative.

If you have voluntarily submitted your information via one of our Websites through an information request form, newsletter sign up, or contact us email, then you may be receiving promotional marketing communications from Inuvo.

At any time, you can unsubscribe directly from any of these communications by following the opt-out instructions included within the footer of the communication received.

Opt-Out • Opt-Out Of Inuvo Interest Based Advertising

If you would like to opt-out of Inuvo Interest Based Advertising, please click on this link. Once you have opted out, an opt-out cookie will be placed on your browser. The opt-out cookie means you will not be retargeted by ads served through our Advertising Technology Products. If You delete, block or otherwise restrict cookies, or if you use a different computer, mobile device or Internet browser, you may need to renew this opt-out choice. However, if you do choose to opt-in, the opt-out cookie will be deleted and you may again be retargeted with relevant advertisement based on your visits to websites of our advertising clients.

Opt-Out • Opt-Out Of Inuvo CTV Based Advertising

To learn more about opting out of CTV targeting please go to: https://www.networkadvertising.org/internet-connected-tv-choices/

Opt-Out • Mobile Application Opt-Out

Mobile devices allow users to opt-out of the collection of usage information within their mobile apps. You can choose to opt-out in your device settings by selecting “Opt out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices.

INFORMATION RELATED TO CHILDREN

Our products and services are designated for a business audiences, and those that are 21 years of age or older. We do not knowingly collect data from children under the age of 16. If you are under 16, do not use or provide any information on our Websites or through any of its features, register on the Websites, make any purchases through the Websites, use any of the interactive or public comment features of the Websites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@inuvo.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see California Data Privacy Rights section for more information.

CALIFORNIA DATA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are 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 send an email to privacy@inuvo.com

We adopt this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. This section applies solely to all visitors, users, and others who reside in the State of California.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

The types of information we collect from consumers varies for our Website users, consumers who interact with a ValidClick powered advertisement, and consumers who interact with an IntentKey powered advertisement.  In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

 

 

Information Category	Examples	Category Collected	What Information We Collect
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Website Users – YES   ValidClick – YES   IntentKey – YES	Website Users- Name, e-mail address, address, in each case if provided to us by the Website User.   ValidClick- Cookie ID; Internet Protocol address   IntentKey- Cookie ID
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, 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.	Website Users – YES   ValidClick – NO   IntentKey – NO	Website Users- Name, e-mail address, address, in each case if provided to us by the Website User.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Website Users – NO   ValidClick – NO   IntentKey – NO	n/a
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Website users – YES   ValidClick – YES   IntentKey – YES	Website Users – Online viewing activity and interaction with advertisements.   ValidClick – Online viewing activity and interaction with advertisements.   IntentKey – Online viewing activity and interaction with advertisements.
G. Geolocation data.	Physical location or movements.	Website users – YES   ValidClick – YES   IntentKey – NO	Website Users- Location information based on IP address   ValidClick- Location information based on IP address
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Website users – NO   ValidClick – NO   IntentKey – NO	n/a

 

Our Websites and Advertising Technology Products obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Websites and / or advertisements.

 

Use of Personal Information

 

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
• To provide, support, personalize, and develop our Websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our [Website users/consumers] is among the assets transferred.

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 share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

The CCPA defines “sale” very broadly and includes the sharing of CCPA PI for anything of value.  According to this broad definition, we may also share your Personal Information by selling it to third parties, subject to your right to opt-out of those sales. In the preceding twelve (12) months, Company has sold the following categories of Personal Information to the categories of third parties indicated in the chart below.

l Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Website Users- Yes ValidClick- Yes IntentKey- Yes	Website Users – Yes ValidClick – Yes IntentKey – Yes
B: California Customer Records Personal Information categories.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
C: Protected classification characteristics under California or federal law.	Website Users- No	Website Users- No
D: Commercial information.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
E: Biometric information.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
F: Internet or other similar network activity.	Website Users- Yes ValidClick – Yes IntentKey – No	Website Users- Yes ValidClick – Yes IntentKey – No
G: Geolocation data.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
H: Sensory data.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
I: Professional or employment-related information.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
J: Non-public education information.	Website Users- No ValidClick – No IntentKey – No	Website Users- No ValidClick – No IntentKey – No
K: Inferences drawn from other Personal Information.	Website Users- No ValidClick – No IntentKey – Yes	Website Users- No ValidClick – No IntentKey – Yes

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

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 12 months (the “right to know”). Once we receive your request and confirm your identity, 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 or selling that Personal Information.·        The categories of third parties with whom we share that Personal Information.·        If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:·       sales, identifying the Personal Information categories that each category of recipient purchased; and·       disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.·        The specific pieces of Personal Information we collected about you (also called a data portability request).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 (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:1.     Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.2.     Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.3.     Debug products to identify and repair errors that impair existing intended functionality.4.     Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.5.     Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).6.     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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.7.     Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.8.     Comply with a legal obligation.9.     Make other internal and lawful uses of that information that are compatible with the context in which you provided it.We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.We do not provide these deletion rights for B2B Personal Information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Address 1:

Inuvo, Inc.
500 President Clinton Avenue
Suite 300
Little Rock AR 72201
Attn: Privacy Officer

Address 2:

privacy@inuvo.com
or you may call our toll-free number at (800) 583-1560.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. You have the right to make or obtain one transportable copy, no more than twice in a twelve-month period, of your Personal Information that we have collected in the period that is 12 months prior to the request date.

When you assert your right to request information, you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include confirmation that you are a resident of the State of California.  We reserve the right to request that you provide further evidence as a resident of California before acting on your request. 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 that the Personal Information relates to you. Any request you submit to us is subject to an identification and residency verification process and must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. For more information on why we have collected data about you, please see the rest of this Privacy Policy and our Terms.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your 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.

To opt-out of this site selling any of the information it collects about you to third parties and to delete all such information, we offer an “Opt-Out” Option, which can be accessed via the following page: https://optout.networkadvertising.org/.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

USERS FROM OUTSIDE THE UNITED STATES

Visitors to our Websites from outside the United States will have their data transferred to and stored in our servers in the U.S. By using our Websites, international users are acknowledging and/or consenting to, to the extent possible, our use and collection of their data as described herein.

The EU General Data Protection Regulation (GDPR)

Effective May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) will be in effect through the EEA, Switzerland, and the UK. The GDPR requires us to provide users in the EEA, Switzerland or the UK with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, precise location data, and biometric data.

Legal Basis for Processing Personal Data

The legal grounds for us processing your Personal Data for the purposes set out in this Privacy Policy will typically be because:

• You provided your consent. On certain occasions, we rely on the consent of the individual to process Personal Data (for example, when the user inputs Personal Information into our Websites).  We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal;
• The processing is in our legitimate interest .In some cases, we rely on legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. We also rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed;
• Contractual relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
• Legal obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

Transfers of Personal Data

We are based in the US and the information we is processed on our servers in the US and other jurisdictions.  When we transfer Personal Data outside of the EEA, Switzerland, or the UK, we take steps to ensure appropriate safeguards are in place to protect your Personal Data.

Your Rights as a Data Subject

The GDPR provides you with the right to access, rectify, or erase any personal data we have collected about you through the operation of our business. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the operation of our business. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Further, if we are processing your information on behalf of one of our clients, we will refer you to that client, and will support them to the extent required by applicable law in responding to your request. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

Data Controller and a Data Processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers hold primary responsibility for your Personal Data.

We may act as either a data controller or a data processor in handling your Personal Data, depending on the precise circumstances. For instance, for Personal Data that we collect from Account Holders, we are a data controller. But when we handle Personal Data strictly on behalf of our Publishers in order to provide our services to them we are a data processor. Thus, for instance, if you have questions about data that is collected and used primarily by Publishers you should contact those Publishers directly regarding questions about the Personal Data they handle and control.

Questions or Concerns

If you are a resident of the EEA, Switzerland, or the UK and have concerns regarding this Privacy Policy, you may contact our privacy officer by email at privacy@inuvo.com or mailing the following address:

 

Inuvo, Inc.

500 President Clinton Avenue

Suite 300

Little Rock AR 72201

Attn: Privacy Officer

 

RIGHT TO CHANGE POLICY

We reserve the right to modify this privacy statement at our discretion at any time, so please review it frequently. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acknowledgement and, to the extent permitted by law, acceptance of such changes.

 

CONTACT US

If you have questions about our privacy policy, please contact us at privacy@inuvo.com or by mail at:

Inuvo, Inc. Attn: Marketing and Communications, 500 President Clinton Ave, Suite 300, Little Rock, AR 72201

 

Updated April 29, 2022