Last updated: October 05, 2023

 A. OVERVIEW

 

At Crigloo, (the “Company,” “Crigloo,” “we,” “us,” or “our”), we have built an omnichannel optimization platform that is super easy to use and yet powerful. This Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, and safeguard the information you provide to us.

This policy describes the data we process when you use the crigloo.com website (the “Site”), as well as our Technology Platform (the Crigloo “Services”)..

Crigloo is the “data controller,” as defined by the EU General Data Protection Regulation for the Personal Data (defined below) collected via the Crigloo Site and Services.

If you have a disability which prevents you from electronically accessing this privacy policy and require it to be provided in alternative format (e.g., audio, large print), you can send us a message at info((at))crigloo((dot))com (info@crigloo.com) for assistance.

By accessing our Site or our Services, you accept our Privacy Policy and Terms of Use.

B. INFORMATION WE COLLECT

 

1. Information you provide us when you register for an account
 

We may collect certain identifying information from visitors to our Site who wish to obtain information or support, or to purchase our Services (“Personal Data”). We collect Personal Data via browser forms, online order forms, or email. Personal Data collected includes first name, last name, business email address, job title, name of your organization, country, business phone number, and payment information.

2. Information collected automatically
 

In an ongoing effort to better understand our visitors to our Site and Services, and how they interact with our Site and Services, we may analyze your information in aggregate form to operate, maintain, manage, and improve our Site and Services. This aggregate data does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. Crigloo and its Sub Processors may also automatically collect certain information about you when you access or use the Site or Services (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Site or Services, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, Crigloo does not consider Usage Information to be Personal Data. The methods that may be used on the Site or Services to collect Usage Information include:

  • Log Information: Log information is data about your use of the Site or Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
  • Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Site, our e-mails, or the Service.
Some information about your use of the Site, the Service, and certain Third-Party Services (defined below) may be collected using tracking technologies across time and services and used by Crigloo and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Website and certain Third-Party Services. We do not recognize browser “Do Not Track” signals.
 

3. Information Collected Via our Technologies
 
Our Services serve both brands and agencies by allowing them to launch campaigns in search, display, and social media platforms. Through our interface, you can set the budget, timeframe, message, and audience details for your ad campaigns. Our tools help our clients to seamlessly conduct multi-channel campaigns while optimizing ad budget.
 
In order to provide our Services to our clients, we use cookies and other similar technologies that place small pieces of HTML code on a webpage to collect information about advertising impression opportunities and displayed ads or website/mobile app traffic (our “Technology”). The following categories of data are collected when these technologies are deployed when providing our Services to customers:
 
  • Standard HTTP header information: This includes IP address, referring URL, user agent data (data transmitted by your browser about itself when submitting an HTTP request), and other data including browser configuration parameters, browser type and language, session storage and local storage settings, and characteristics of your device such as the CPU class and time zone setting.
  • Information contained within an advertisement: This is known as an “ad tag,” that includes information used to identify the advertiser displaying the ad and the media property that sold the impression.

C. HOW WE USE THE DATA WE COLLECT

 

We use the information we collect to for the following purposes:

  • To deliver our Services to customers.
  • To enhance our Site and Services.
  • To process your registration and manage your account.
  • To transact with you, provide the Site, Services, or information you request, respond to your comments and questions, serve you content and/or advertising, and send you notices.
  • To improve the Site and Services.
  • To tailor our content, advertisements, and offers.
  • To fulfill other purposes disclosed at the time you provide Personal Data or otherwise where we are legally permitted or are required to do so.
  • To prevent and address fraud, breach of policies or terms, and threats of harm.

D. HOW AND WHY WE DISCLOSE YOUR PERSONAL DATA

 

1. Disclosures to Third Parties
 

Like many businesses, we hire other companies to perform certain business-related services. We may disclose Personal Data to certain types of third-party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive Personal Data and their functions include: data storage and hosting services, customer relationship management services, cloud application providers, and disaster recovery services. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by Crigloo.

2. Disclosures to Affiliates
 

We may also disclose Personal Data to our affiliates in order to support the marketing, sale, and delivery of our Services. Personal Data may be disclosed between affiliate, subsidiary, and parent organizations of Crigloo.

3. Business Disclosures
 

Crigloo may share your Personal Data, in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Crigloo’s assets, or transfer of all or a portion of Crigloo’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

4. Disclosures to Public Authorities
 

We may share your Personal Data to comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request. We may also disclose Personal Data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

E. THIRD-PARTY CONTENT, SERVICES, ANALYTICS, AND SOCIAL FEATURES

 

The Site may include hyperlinks to websites, platforms, applications, or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other tracking technologies to independently collect information about you and may solicit Personal Data from you.

Certain functionalities on the Site permit interactions that you initiate between the Site and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include “liking” or “sharing” Crigloo’s content or logging in to the Service using a Third-Party account (e.g., using Facebook to sign in to the Service). If you post information on a Third-Party service that references Crigloo (e.g., by using a hashtag associated with Crigloo in a tweet or status update), your post may be used on or in connection with the Site, or otherwise by Crigloo. Also, both Crigloo and the Third-Party may have access to certain information about you and your use of the Service, the Site, and other Third-Party Services.

Crigloo may engage and work with Sub Processors and other Third Parties to serve advertisements on Third-Party Services. Some of these ads may be tailored to your interests based on your browsing of the Site and elsewhere on the Internet, which may include use of precise location and/or cross-device data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a Third-Party Service after you have left the Site (i.e., “retargeting”).

Crigloo may use Google Analytics or other Sub Processors for analytics services. These analytics services may use cookies and other tracking technologies to help Crigloo analyze Site users and how they use the Site. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by Sub Processors on servers in the U.S. (or elsewhere) and these Sub Processors may use this information for purposes such as evaluating your use of the Site, compiling statistic reports on the Site’s activity, and providing other services relating to Site activity and other Internet usage. You may opt out of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Crigloo, the types of information shared, and your choices on what is visible to others on Third-Party Services. Crigloo is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Sub Processors and Third-Party Services associated with the Site. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Some of the advertisers and Service Providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks) or non-targeted advertisements. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser, or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Crigloo supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expects that ad networks Crigloo directly engages to serve you Interest-based Advertising will do so as well, though Crigloo cannot guarantee their compliance. Crigloo is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

F. DATA SUBJECT RIGHTS

 

The law in some jurisdictions provides individuals in those jurisdictions with certain rights regarding their Personal Data. Subject to certain exceptions, you have the right to ask Crigloo to:

  • Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
  • Update or correct inaccuracies in your Personal Data.
  • Delete your Personal Data.
  • Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
  • Restrict the processing of your Personal Data.
  • Object to our processing of your Personal Data for direct marketing purposes.
  • Obtain information about and object to our reliance on our legitimate interests as the basis for processing of your Personal Data.
You can submit these requests via email at info@crigloo.com. We may request information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you have questions regarding our Personal Data processing or if you’d like to submit a complaint, you may contact us at info@crigloo.com. We will do our best to resolve any questions or concerns that you have. You may also submit a complaint to the data protection regulator in your jurisdiction.
 

G. LEGAL BASES FOR PROCESSING

 

Our processing of your Personal Data is carried out pursuant to the following legal bases:

  • The processing is necessary for us to provide you with the Services you request, or to respond to your inquiries.
  • We have a legal obligation to process your Personal Data, such as compliance with applicable tax and other government regulations or compliance with a court order or binding law enforcement request.
  • We have a legitimate interest in carrying out the processing activity. In particular, we have a legitimate interest in the following cases:
  • To analyze and improve the safety and security of the Site and Services. This includes implementing and enhancing security measures and safeguards and protecting against fraud, spam, and abuse.
  • To maintain and improve the Site and Services.
  • To operate the Site and Services and provide you with certain information and communications tailored to, and in accordance with, your preferences.
  • You have consented to the processing of your Personal Data. When you consent, you may change your mind at any time.
H. CHILDREN’S PRIVACY

Neither the Site nor the Service are directed to anyone under the age of 13. We do not knowingly collect information from anyone under the age of 13. If you are under the age of 13, please do not provide us with any Personal Data. In the event that we learn that we have gathered Personal Data from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at: info@crigloo.com.

I. HOW WE PROTECT INFORMATION

We take the security and privacy of the Personal Data that we collect pursuant to this Privacy Policy very seriously. Accordingly, we will implement reasonable and appropriate security measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of the information, and compliance with applicable laws and regulations.
 

J. MARKETING COMMUNICATIONS

 
You have the right at any time to opt out of marketing emails by following the unsubscribe instructions provided in each promotional email. You can also indicate that you do not wish to receive marketing communications from us in your profile page of the Service. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the profile page of the Service, we may continue to send you administrative emails including, for example, information regarding your Crigloo Services.
 

K. YOUR CALIFORNIA PRIVACY RIGHTS

 
Under California’s Shine the Light law, pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of Personal Data that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. Please note that we are only required to respond to one request per individual each year, and we are not required to respond to requests made by means other than through this email or mail address.
 
For more information regarding your California privacy rights, you may email us at info@crigloo.com. You may also write to us at: 25225 SE 42 nd Dr. Sammamish, WA, 98029: (Attn: General Counsel).
 

L. INTERNATIONAL TRANSFERS

 
If you are located outside of the U.S. or India, please be aware that any information provided to us or collected by us, including Personal Data, will be transferred from your country of origin to the U.S. and India, as our servers are located in the U.S. and India. Please note that these jurisdictions may not offer the same level of data protection as your country of residence, although our collection, storage, and use of your Personal Data will continue to be governed by this Privacy Policy.
 

M. CHANGES TO OUR PRIVACY POLICY

 
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on our Site and Service as soon as they go into effect. By accessing our Site or Service after we make any changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer to this Privacy Policy on a regular basis.
 

N. CONTACT US

 
If you have any questions regarding this Privacy Policy, please contact us by sending an email to: info@crigloo.com.