Everflow Platform Services Privacy Policy

(last updated May 21, 2018)

Everflow Technologies Inc. (“Everflow”, “we”, “us”, “our”) provides this Privacy Policy to inform users of our policies and procedures regarding the collection, use and disclosure of information through the Everflow web-based advertising network, affiliate tracking, targeting, reporting and analytics services (the “Platform Services”). Please note that this Privacy Policy only applies to the Platform Services. The Privacy Policy for Everflow’s corporate website is here: https://everflow.io.

Throughout this Privacy Policy, when we use the words “you”, “your”, or “user”, we mean an individual viewing ads displayed using the Platform Services. 

Everflow Customers and Your Rights

Everflow emphasizes that this Privacy Policy does not address the practices or policies of its Platform Services customers (“Everflow Customers”), nor of any website, mobile app, or other property on which ads are displayed using the Platform Services. Everflow is solely a technology and tools provider and does not engage in brokering, displaying or executing any ad campaign. Everflow Customers use the Platform Services and collect and process personal data for the legitimate interest of marketing to individuals.

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

Each Everflow Customer is the data controller with respect to all such data, and the applicable data protection officer (if any) will be someone appointed by the Everflow Customer. 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 an Everflow 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. If you have trouble reaching the relevant Everflow Customer directly, please contact Everflow at the email address below.

If you are a resident in the European Union, you also have the right to at no cost to lodge a complaint with EU data protection authorities. This right may also exist in other countries. If you have questions please ask the relevant Everflow Customer or the data protection authority in your country.

How Do Everflow Customers Collect User Information Using Everflow?

The Everflow Platform Services allow Everflow Customers to collect various kinds of information about users.

Everflow 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. Everflow also supports server-to-server measurement for some Everflow 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 Everflow Customer chooses to monitor, the Everflow Platform Services collect information from the 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 a user through the Platform Services or when a user views a web page with a cookie or pixel tag creates with the Platform Services. Log Data may include information such as a user’s Internet Protocol (IP) address and network status, mobile device identifier, application identifier, browser type, operating system, the pages or page features to which a user browsed and the time spent on those pages or features, frequency with which the Platform Services encounter the same user, search terms, the links or advertisements on which a 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 “Can I Opt 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). 

How Do Everflow Customers Use Everflow To Process Information From Users?

As we indicated at the beginning of this Privacy Policy, Everflow Customers use information according to their own privacy policies and applicable law and regulation. However, Everflow provides the following types of data analysis functionality within the Everflow Platform Services for use by Everflow Customers and only as directed by Everflow Customers:

How Does Everflow Use Collected Information?

We use the information collected through the Platform Services to provide, improve, and promote the Platform Services. Uses include the following.

How Long Does Everflow Retain Data

Each Everflow Customer sets the personal data retention period. If you have questions or want more details, please contact the relevant Everflow Customer. Everflow retains personal data that it processes on behalf of each Everflow Customer for as long as needed to provide services to that Everflow Customer. Everflow will also retain personal data as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

What Information Does Everflow Share With Third Parties?

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 information collected through the Platform Services 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. Information collected through the Platform Services including 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, all of the information collected through the Platform Services 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 from having your privacy violated through 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 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.

Disabling Cookies

Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting some or all cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of certain websites. 

Can I Opt Out of Targeted Advertising?

Everflow Customers may use the Platform Services to provide ads that are likely to be more interesting and more relevant to users. One way Everflow Customers may do this is by collecting information related to 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 Everflow Customer, information collected by third parties or Everflow and shared with the Everflow Customers, advertising identifiers, or location information (i.e.GPS or Wi-Fi data if you have enabled those services). Everflow Customers may also link an identifier to additional information from other partners to provide the Everflow Customer with information about users’ likely interests. 

If you wish to "opt out" of certain advertising targeted using the types of techniques described aove, you have several choices:

You should be aware that if you “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.

What Information Does Everflow Collect Directly From Everflow Customers?

Everflow requires personnel contact details to set up an Everflow Customer account – including mailing and/or billing address, email address, company name, and website URL. Everflow Customers will also need to provide a user name and password. All of this information is handled according to the service agreement between Everflow and the Everflow Customer.

The Security of Your Information

We take reasonable measures to protect from unauthorized access, use or disclosure the information that we collect. 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.

International Transfer

Your information (including personally identifiable information) may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. 

Privacy Shield

Everflow is actively working on attaining EU-U.S. and Swiss-U.S. Privacy Shield certification with respect to the personal data we receive and process through our services and we will update this document once we've received that certification. Everflow certifies that it adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for the personal data of individuals in participating European countries.

Our Policy Toward Children

We instruct Everflow Customers not to use the Platform Services to direct advertising to children under 13 (16 in the EU) and we do not knowingly collect personally identifiable information from children under 13 (16 in the EU). If we learn that we have collected personally identifiable information of a child under 13 (16 in the EU) we will take steps to delete such information from our files as soon as possible.

Changes to Privacy Policy

Any information that we collect is subject to the privacy policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll provide notice of such changes by posting them here, and we’ll indicate when such changes will become effective. Information will continue to be governed by the Privacy Policy in effect at the time such information was collected.

Questions?

Please contact us at privacy@everflow.io if you have any questions about our Privacy Policy.