I. Information We Collect: Lead Originators And Lead Buyers.
A. Personally Identifiable Information.
SmartLeadsMedia, Inc. (“SmartLeadsMedia”) collects personally identifiable information from all Lead Originators and Lead Buyers (collectively “Clients”) wishing to work with us. The collection of this information is a part of our normal business practices. Clients or their representatives will be asked to provide personally identifiable data through the host sign up and registration process. Examples of personally identifiable data that may be requested include name, address, phone number, email address, social security number, tax ID number, credit card number, etc. SmartLeadsMedia will never request or collect data from a Client on subject areas including medical/health conditions; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership or sex life.
B. Non-Personally Identifiable Information.
II. Information Sharing
SmartLeadsMedia does not use any personally identifiable data about a Client for profiling purposes. All personally identifiable information that SmartLeadsMedia collects from Clients is principally intended for administration needs (e.g., accounting and pay-out), for which purpose such data are required.
SmartLeadsMedia may receive personally identifiable information of third-parties that Clients have collected for transmittal to other Clients. Each Client has agreed that it has provided notice to, and obtained consent from, any third-party individuals whose personal data it supplies to SmartLeadsMedia with regard to: (a) the purposes for which such third-party’s personal data has been collected; (b) the intended recipients or categories of recipients of the third-party’s personal data; (c) which of the third-party’s data are obligatory and which data, if any, are voluntary; and (d) how the third-party can access and, if necessary, rectify the data held about them. SmartLeadsMedia may transmit such third-party personally identifiable information to the intended recipients or categories of recipients as requested by such third-party.
While SmartLeadsMedia strongly encourages Clients to adopt responsible approaches to online marketing, SmartLeadsMedia is not responsible for the information practices of Clients or their partners. The collection, use, and disclosure of information by Clients and partners are subject to their respective privacy policies, which may differ from SmartLeadsMedia’s policy.
Periodically, SmartLeadsMedia may use Clients’ personally identifiable information in order to communicate via email newsletters or other avenues to offer information and other communications to assist in business-related activities. In the event that a Client wishes not to have their personally identifiable information used for these purposes, they may elect to opt-out from future communications. For more information on opting-out, please see the “Client Choice And Access” section below.
Except as may be agreed between SmartLeadsMedia and a Client, all personally identifiable information data provided by individual Clients will be kept in strict confidence by SmartLeadsMedia and will be treated with the same level of respect and care that they treat other proprietary information and trade secrets. SmartLeadsMedia will never sell, rent, exchange or barter any personally identifiable Client information to or with any third-party for financial gain or marketing purposes. SmartLeadsMedia may, from time to time, provide such information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services such as billing, delivery and payouts. Any third-party vendor so used has agreed to protect the confidentiality of information provided by SmartLeadsMedia.
SmartLeadsMedia may release account and any other personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law or protect the rights, property, or safety of SmartLeadsMedia or others. This includes exchanging information with other companies and organizations for fraud protection.
III. Client Choice And Access
When a Client registers for services with SmartLeadsMedia, personally identifiable information is required as a part of doing business. SmartLeadsMedia’s primary intent in collecting personally identifiable information is for administrative purposes including accounting and payouts. However, SmartLeadsMedia may periodically use personally identifiable information for marketing and communication purposes targeted to our Clients. Clients wishing not to receive such communications from SmartLeadsMedia may do so by “opting-out” during the registration and application procedure process. A Client may change their “opt” status at anytime during their tenure with SmartLeadsMedia by accessing their online account.
When a Client logs on any browser-based SmartLeadsMedia reporting system, a “Cookie” is placed within their computer. The purpose of the Cookie is to allow SmartLeadsMedia to validate the identity of the Client and maintain the security and privacy of the Client’s account data. This Cookie is required to log into SmartLeadsMedia’s reporting systems and there is no method to opt-out of this Cookie.
SmartLeadsMedia employs industry-standard security measures to ensure the security of all data. Any data that is stored on SmartLeadsMedia’s servers is treated as proprietary and confidential and is not available to the public. SmartLeadsMedia has an internal security policy with respect to the confidentiality of Client data, allowing access only to those employees or third-parties who have a need to know such information. SmartLeadsMedia routinely evaluates its data security practices to identify security threats or opportunities for improvement.
No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third-parties not under the control of SmartLeadsMedia to intercept or access transmissions or private communications unlawfully. While we strive to protect your personally identifiable information, SmartLeadsMedia cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with SmartLeadsMedia.
V. Consent and Changes
VI. Limitation Of Liability, Third-Party Information & Language
You also agree that you have provided notice to, and obtained consent from, any third-party individuals whose personal data you supply to SmartLeadsMedia with regard to: (a) the purposes for which such third-party’s personal data has been collected; (b) the intended recipients or categories of recipients of the third-party’s personal data; (c) which of the third-party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them.
VII. Contact Us
March 1, 2018