1. INTRODUCTION AND SCOPE
XPOLLO operates several search and frequently used content websites with browser addons. We are committed to being transparent and meaningful about the information we collect and use when you use our websites because we understand how important your privacy is to you. This Privacy Statement outlines our procedures with regard to the personal data that is gathered, managed, and retained when you access and utilise browser-based websites.
2. Information We Collect, How We Use It, and How and Why We Share It
This section will serve as the notice at collection as provided in Section 1798.100(b) of the California Consumer Privacy Act.
Access to web search results or other general content on our Sites generally does not require you to create an account.
We may permit our service providers to process your personal data for specified purposes and in accordance with our agreements with them. Such service providers may also engage vendors to help them process user data, so they can provide their services to us. Some third parties who collect data about you through their tags or pixels implemented to our Site pages may also use your data for their own purposes, and in such case we provide you with the ability to consent in countries where such consent is required, or the ability to opt out where such opt out is required.
The chart below describes what data may be automatically collected by third parties when you visit our Sites via code that we implement to our Sites to allow them to access your browser. In certain cases these third parties are co-controllers of personal data with us. We only permit such third parties to collect and process your personal data in accordance with our agreements with them.
|Categories of Personal Information||How third parties collect it||Which Partners collects it||How they use it|
|Cookies, Unique ID Codes and other trackers from ad networks where we promote our Sites and services||Third parties who provide us with advertising services to promote our Sites and search services may also place cookies, ad tags, beacons and other tracking mechanisms on our advertisement landing pages that enable the collection of data about your visits to and actions on our Sites after you clicked on our advertisements.Such information collection and use by third parties via cookies and tracking devices only occurs with your consent where required (such as in the United Kingdom or the European Economic Area). It may qualify as a “sale” of personal information under the California Consumer Privacy Act. For more information and how to opt out of any such “sale”.||Publisher networks where we distribute and display our advertisements to promote our Sites and search services (such as Facebook and Google), and service providers who help us optimize our advertising campaigns (such as re targeting companies).||These third parties collect information about you in order to provide their ad campaign optimization services to us, and may also use such information to develop their own ad targeting algorithms and help other advertisers with optimizing their own campaigns by targeting ads to you based on your activities on our Sites.They may also combine information about your activities on our Sites with information about you from other sources not affiliated with us.|
3. More Details On Information Collected, Purpose of and Basis for Collection
Collection of Information via Cookies and other Tracking Tools.
XPOLLO and service providers acting on our behalf (like Google Analytics, vendors who power our video player or push notification features, and advertising companies we hire to promote our website and apps) use data collection and tracking tools like cookies, web beacons, tags, scripts, customized links, device or browser fingerprints and similar tracking technologies (together, “Tracking Tools“) to gather data when you use our Sites and apps. These Tracking Tools automatically track and collect information about your activities on our SItes.
Cookies are small text files stored by your browser, to collect, store, and share data about your activities across multiple websites. Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are persistent cookies’, meaning that they survive after your browser is closed. They can be used by websites and advertising services to recognize you when you open your browser and browse the Internet again. Cookies can be “first party”, meaning they are served directly by us to your browser or mobile device, or “third party”, meaning they are served by either one of our vendors to provide their services to us, or by an advertising partner when we promote our services.
Strictly Necessary. These Tracking Tools are necessary for our Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.
Functional. These Tracking Tools enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Site Performance and Analytics. These Tracking Tools allow us to count visits and traffic sources so we can measure and understand how our sites are accessed in order to improve the performance of our Sites. These tools can help us test different versions of our Sites to see which features or content users prefer, and determine which of our email messages are opened. These may be first party cookies or third party cookies from our vendors who help us with analytics services. They help us to know which Site pages, content and features are the most and least popular and see how visitors move around within our Sites. If you do not allow these cookies we will not know if and how you have visited our Sites, and will not be able to monitor our performance or improve our services.
Targeting. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They are based on uniquely identifying your browser and device as you access our Sites. If you do not allow these cookies, you will experience less targeted advertising. Such information collection and use by third parties may qualify as a “sale” of personal information under the California Consumer Privacy Act. For more information and how to opt out of any such “sale”, see Opt out of sharing for Interest Based Advertising.
Technical information. As you interact with the Sites, we may collect additional technical information via additional automated means:
- Information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information and operating system or platform
- Your browser preferences and settings (time zone, language, etc.)
- Internet provider or mobile service provider name
This information is also tied to your Browser ID.
Aggregated user information. We routinely aggregate the personal information of all of our users into user usage statistics for our Sites. With this aggregation, your personal data is mixed with other user data and becomes de-identified. We are not able to identify or re-identify you or any particular user. We do not treat de-identified data or aggregate consumer information as personal information and we reserve the right to convert, or permit others to convert, your personal information into deidentified data or aggregate consumer information. Sharing de-identified aggregate data with third parties does not constitute a sale or transfer of personal information.
Legal basis for collection. We collect and use your personal information on the grounds of the legal basis described below:
- Provide our services: we process your personal information to provide our web search and content services. This is so we can comply with our contractual obligations to you.
- Improving our services: we analyze information about how you use our Sites to provide an improved experience for our users, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Sites and improve them.
- Compensating our partners: we process your personal information for purposes of calculating compensation to be paid to our third party product/service providers and distributors and to analyze usage across products, services and distribution partner/channel. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy.
- Communicating with you: we may use your personal information when we communicate with you, for example if we are providing information about changes to the terms and conditions or if you contact us with questions. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Sites and services.
- Exercising our rights: we may use your personal information to exercise our legal rights where it is necessary to do so; for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law.
- Complying with our obligations: we may process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law, such as responding to your request for data access or deletion.
- Customizing your experience, including ads: when you use the Sites, we may use information about your use of the Sites (queries you submitted, content you viewed) to customize your experience, such as by providing personalized elements and showing you content based on your recent interests. We may use automated decision-making for these activities. Upon your affirmative consent or request, we may use your browser information to send you notifications about content on our site via your browser. As required by applicable data protection and privacy laws, we will obtain your consent for these activities or enable you to opt out of these activities.
Third party links. The Sites include many links to third-party websites, services, widgets, ads, and other services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices.
Additional information about Sharing with Third Parties
In addition to the sharing described in the chart above, we share your information with third parties for the purposes described below:
- Fraud prevention: we may disclose your information to third parties when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
- Law enforcement purposes and public safety: if requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- Other IAC businesses: We are part of the IAC family of businesses (go to www.iac.com for a listing of these businesses). We may share information we collect, including personal information, with the IAC companies. Sharing information with our IAC companies enables us to provide you with information about a variety of products and services that might interest you.
- Sale or merger of our business: we may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
Your Opt Out Rights and Choices
You have rights and choices regarding our collection and use of your personal information, as well as the collection and use of some of our third party partners. A few of those choices are set forth below.
Removing our cookie. If you remove our Browser ID cookie from your browser cache, we will no longer recognize your browser and activities until a new cookie is placed. Any future site activities you perform after you delete this cookie will not be tied to your previous activities which were associated with the removed cookie.
You will continue to see advertisements on our Sites, but they will not be tailored to you based on any past behavior on our Sites or other websites. You may, however, still receive customized content and/or ads based on the search queries you submitted or the content of the pages you are visiting.
Removing Interest-based advertising from Mobile Tracking Devices. You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies.
Do Not Track. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
For California users: Opt out of sharing for Interest Based Advertising (“Do Not Sell”).
There is no industry consensus on whether enabling third parties to collect personal data via cookies for interest based targeting is a “sale” under California Consumer Privacy Act. We however want to give you choices regarding third parties using cookies or tracking devices to collect information about your internet usage while you visit our Sites.
Some browsers have signals that may be characterized as Do Not Sell signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you, so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
If you do not wish for our advertising partners and certain data connectivity service providers to collect your personal information for interest based advertising purposes, click the button below to “Opt Out”. We manage Opt Out requests on a per browser basis, using your Browser ID cookie. This means that we need access to your browser when you click on the Opt Out button below in order to respond to your Opt Out request. We therefore cannot process any Opt Out request from a third party acting as your agent.Opt Out of Third Party Sharing for Interest Based Advertising
This function is not activated if you do not have a California IP address. If the button is not active, please try again from a California location.
Your Access, Revision & Deletion Rights
Right to know/right of access
If you are located in the European Economic Area (EEA), the United Kingdom, in California, or in certain other states, you have specific rights to know and have access to the personal information that has been collected and stored by the web properties that you visit (and in the EEA, right to correct such information). Your rights can only be exercised if such web properties can adequately verify that you are the same person as the user whose data is being requested.For Sites that do not require you to provide us with your email address, we do not collect sufficient data to authenticate any particular user. We only recognize a unique browser based on the Browser ID we assign to that browser for a particular Site. A Browser ID could therefore correspond to multiple individuals. In the same way, one user could have multiple unique browser IDs if they visit multiple Sites or visit the same Sites with multiple devices or browsers. Since the personal information we collect related to a Browser ID is not sufficient to verify that the corresponding browser belongs to the person making the request, we are not able to provide any information in response to any request to know or access specific personal information about a user. This is to prevent anyone from using your browser to obtain your search or browsing history. We want to make sure your search and browsing history does not fall into the wrong hands.
However, upon your request, and provided you are able to provide to us your Browser ID, then we may provide you with the following information collected within the last 12 months:
- Which categories of personal information we have collected about you (based on your Browser ID or other information you have provided to us), and how we collected that information, as well as the business or commercial purposes for our collecting such personal information.
- A list of the categories of personal information shared with third parties for a business purpose and the categories of third parties to whom we have shared your personal information.
- A list of categories of personal information that may have been collected by third parties when you visited our Site, and the categories of third parties who may have collected such information.
Information relating to your Browser ID is retained by us for various time periods, so we may not be able to provide information for the full 12 months preceding your request.
If you have provided to us your email address to subscribe to one of our newsletters, your email is not automatically tied to your Browser ID, and therefore you have to request us to delete your email separately.
If you have created an account with one of our Sites, and we are able to authenticate your account via your email address, then we are able to provide to you a log of all of your activities on the Site that is tied to your account for that Site.
Right to delete
If you are located in the European Economic Area (EEA), the United Kingdom, California, or in certain other states, you have specific rights to request us to delete any personal information we have stored about you. In the EEA, you also have the right to withdraw any consent that you have previously provided to us to store or use your personal information. As indicated above, since all personal information we have is tied to your Browser ID, we are only able to delete your personal information from our databases if you can provide to us that Browser ID. You can also request deletion of certain other information that is not tied to your Browser ID as further described below.
All requests for access or deletion will be reviewed by our legal and compliance team and we reserve the right, in compliance with applicable laws, to accept or reject, or make further inquiries regarding, any requests. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if it is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Data Hosted in the United States
By visiting or using our Sites, your data is automatically collected, processed and stored on servers located in the United States. If you are located in the United Kingdom (“UK”), Switzerland, or the European Economic Area (“EEA”), this means your data is stored in a country the laws of which may offer less personal data protection than your country. We however comply with requirements set forth in the EU General Data Protection Regulation when we process your data, and you have the right to lodge a complaint with the data supervisory authority of your country if you feel that we have unlawfully processed your data.
Non Discrimination, Complaints and Disputes
We commit to resolve complaints about your privacy and our collection or use of your personal information. Inquiries, concerns or complaints may be submitted to us.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not satisfactorily addressed your complaint or concern, you may have the right to make a complaint to the data protection authority of your state of residence. XPOLLO is further subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) in the United States.
Data Retention and Security
We have designed our Browser ID system so that we can manage our Sites while collecting as little information about our users as possible. We generally retain the information tied to your Browser ID for a period of fourteen (14) months, unless necessary for the purpose of satisfying any legal, accounting, or reporting requirements for example to resolve disputes and enforce our agreements.
If you subscribe to one of our Sites’ email communications and provide us your email address, we will keep your email address for as long as you open our email communications and six months after your email address becomes unresponsive to our emails or when you unsubscribe.
If you have created an account with one of our Sites, we retain all information associated with your account for 60 days after your account is terminated, unless you instruct us otherwise, after which your account activity data remains but is anonymized and no longer tied to your email address, account ID, or any other information that may identify you.
We take the security of your information seriously and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to information about you to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.
Data Protection Officer