PRIVACY POLICY

As used herein, “Programmatic Connect” refers to the Programmatic Connect service, and affiliate sites, subdomains, mobile version(s), associated applications and any other services under the Programmatic Connect name and that are owned and/or operated by Programmatic Connect LLC, a New York Limited Liability Company, and its affiliates (collectively, “us”, “we” or “Programmatic Connect”). By using Programmatic Connect, you indicate your acceptance of this Terms and Conditions for Accessing Programmatic Connect and Privacy Policy. If you do not agree to the Terms and Conditions for Accessing Programmatic Connect and Privacy Policy, you are not permitted to access Programmatic Connect and you should not do so.
 
PLEASE READ AND UNDERSTAND THE TERMS AND CONDITIONS FOR ACCESSING PROGRAMMATIC CONNECT AND THE PRIVACY POLICY. THE ACT BY YOU OF ACCESSING THE PROGRAMMATIC CONNECT SERVICE, USING ANY PART OF THE CONTENTS OF THE PROGRAMMATIC CONNECT SERVICE, USING ANY PART OF THE SERVICES THEREON, FOLLOWING ANY LINK ON PROGRAMMATIC CONNECT OR MAKING ANY PURCHASE ON PROGRAMMATIC CONNECT OR ON ANY OTHER WEBSITE ACCESSED THROUGH A LINK FROM PROGRAMMATIC CONNECT CONSTITUTES YOUR EXPRESS ACCEPTANCE OF ALL TERMS AND CONDITIONS OF USE TO THE EXCLUSION OF ANY TERMS AND CONDITIONS NOT EXPRESSLY SPECIFIED HEREIN.
 
We reserve the right to change or otherwise update this Terms and Conditions for Accessing Programmatic Connect and the Privacy Policy at any time. Such changes or updates are effective immediately after we give notice of the change or update, which we may do by revising the “Last Updated” date of this Terms and Conditions for Accessing Programmatic Connect and the Privacy Policy or by otherwise posting on Programmatic Connect, or by email or conventional mail, and/or by any other means which provides reasonable notice. Your use of Programmatic Connect after such notice is posted means that you accept these changes or updates. You agree that Programmatic Connect shall not be liable to you for any damages that might result from any changes to the Terms and Conditions for Accessing Programmatic Connect and the Privacy Policy, if any.
 
Programmatic Connect aggregates useful and attention-grabbing information from third party internet companies that is made available to display in an accessible hands-free manner. We understand and respect your desire for privacy online and offline. To that end, we would like you to know how
we use the information you consent to provide us:
 
We collect personally identifying information when you register for Programmatic Connect. This personally identifiable information may include, without limitation, your Name, Address, Phone Number and E-mail address. We capture non-personally-identifiable information such as device ID (i.e. IDFA & GAAID) after login and during use to administer Programmatic Connect and to compile aggregate information about usage of Programmatic Connect, as well as, device GPS location (i.e.
Latitude/Longitude) and IP address to cultivate and deliver location specific content. 
 
Use sensitive data from camera sensors to detect unidentifiable facial features which enables software overlay to display content at the opportune time. We are using Google Vision SDK for facial feature detection and not using cloud vision services. Proprietary image recognition analyzes anonymized imagery in real-time without having to be stored on any servers.
 
Deploy security protocols that protects from un-authorized usage by known entities and organization, encrypt connections with some of the same technology used by banks in order to protect our information. (Handle all personal or sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS). We maintain Programmatic Connect in a manner to help prevent unauthorized access, maintain data security and to make proper use of the information that we collect. However, no transmission of data over the Internet is guaranteed to be completely secure. Thus, while we strive to protect your personal information, we cannot absolutely guarantee the security of any information you provide to us.
 
Programmatic Connect post advertisements or other material from third-party sites and does not assume any responsibility or liability whatsoever with reference to any advertisement, content, purchase or other interaction with a third-party. You are responsible for what is displayed that can be viewed by persons’ in close proximity. Be sure to review all privacy policies and other terms of use published by our third-party sites and contact them directly if you have questions as they may have privacy terms or other terms of use that differ from our Privacy Policy. The third-party site is completely responsible for its content and your access of it.
 
Links to privacy policy of third-party service providers used by the app:
 
POLICY FOR MINORS

The fact that you have signed on Programmatic Connect means that you are representing to us that 
you are at least 13 years old and if you are not yet 18 years old that you have the consent of your parent or guardian to access Programmatic Connect. If you are not at least 13 years of age or if you are under 18 years of age and do not have the consent of your parent or guardian to be on Programmatic Connect, you do not have permission to be on Programmatic Connect and we require that exit Programmatic Connect immediately. No information should be submitted to Programmatic Connect by any person who is not at least 13 years of age or by a Minor (a user under 18 years of age) without parental consent. Unless otherwise disclosed during collection, we do not knowingly provide any personally identifying information about Minors, regardless of its source, to third parties, nor is this information knowingly used by us for any marketing or promotional purposes.
 
POLICY FOR ADULT USERS 
 
We may collect personal information from Programmatic Connect users over 18 years of age in order to provide users with a personalized online experience. We may share the personal and aggregate information we collect with our affiliates and other sites operated by and for us. On a confidential basis, we may also share personal information with our corporate affiliates or consultants, or with third parties that perform a particular service on our behalf (such as fulfilling orders or for general administration purposes for Programmatic Connect). We may elect to share aggregate information with third parties for marketing and promotional purposes. If all or part of Programmatic Connect is merged or is otherwise transferred to another entity, the information you have provided on or through Programmatic Connect may be transferred to such entity as part of that transaction. We may also disclose personal information in response to legal process, such as a request by law enforcement, a court order or subpoena, or to protect the integrity of Programmatic Connect if we believe that a user has committed unlawful or otherwise harmful acts.
 
With the permission of users 18 years or older, information submitted at the time of registration or submission may be used for marketing and promotional purposes by us.
 
If any individual submits content for publication, we may publish his or her name and any other information submitted by that individual.
 
YOUR CALIFORNIA PRIVACY RIGHTS
 
A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal information if it shares such information with third parties for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and by providing a cost-free means to exercise that right.
 
As stated earlier in this Privacy Policy, personal information submitted at the time of registration or submission may be used for marketing and promotional purposes only with the user’s permission. Whenever a user agrees to allow us to collect personal information, we provide the user with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time e mailing the email address below:
 
Email: if you wish to opt-out.
 
Because Programmatic Connect has a comprehensive privacy policy and provides you with details on how you may opt-in or opt-out of the use of your personal information by third parties for direct marketing purposes, we are not required to provide you with the third party list., You may opt out this cost-free at any time by mailing the email address below:
 
Email: if you wish to opt-out.
 
PURCHASE OF PRODUCTS OR SERVICES FROM PROGRAMMATIC CONNECT
 
If you purchase a product or service from Programmatic Connect, information may be collected from you, including your credit card and contact information, for transfer to and use by third party providers of the product or service. Unless otherwise stated, we do not have any responsibility in connection with such purchases and all transactions and use of any customer information are the sole responsibility of the product/service provider. Be sure to review the product/service provider’s privacy policy and contact them directly if you have any questions. They may have privacy terms that differ from our Privacy Policy.
 
LINKS TO THIRD PARTY SITES
 
Programmatic Connect may contain links to other sites. Please be aware that Programmatic Connect is not responsible for the privacy and other practices of such other sites. Programmatic Connect is not responsible for the quality or suitability of products purchased from other websites, for delay and/or errors in shipping products purchased from other websites or for any other problems or disputes arising from your using a link on Programmatic Connect to another website. We encourage our users to be aware when they leave Programmatic Connect and to read the privacy statements, terms of use and rules and procedures concerning purchases made from each and every website accessed through a link on Programmatic Connect. This statement of Terms and Conditions for Accessing Service and Privacy Policy applies solely to Programmatic Connect.
 
USE OF IP ADDRESSES
 
An IP address is a number that is automatically assigned to your computer by your Internet service provider whenever you log on to the Web. Web servers automatically identify your computer by its IP address, so when a user requests pages from the Website, our servers log the user’s IP address. The IP addresses of our users are collected only for the purposes of system administration and to report aggregate information to our advertisers, our corporate affiliates or consultants, or with third parties that perform a particular service on our behalf. We do not combine IP addresses with any personally identifying information, nor do we compile any session activity reports by IP address.
 
USE OF COOKIES
 
Cookies
In cyberspace, cookies are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. 
 
Cookies make web surfing easier for you by saving your passwords, purchases and preferences while you’re online. The use of cookies is an industry standard. You’ll find them at most major websites.
 
We use cookies to help us see which areas are popular and which are not. This helps us to improve and update Programmatic Connect based on such data as total number of users and pages viewed. This information is most easily tracked with cookies.
 
A cookie allows us to store the personal preferences that you set during each visit to the service, which in turn allows us to speed up your future activities at Programmatic Connect. Similarly, the stores hosted by Programmatic Connect usually use cookies to track which products, services or virtual gifts you’ve chosen to purchase while shopping, if any. Letting cookies do the record keeping saves you the trouble of entering information over and over again. If you have registered to access the subscriber-only portion of Programmatic Connect, an identifying cookie will be placed on your computer. During future visits to Programmatic Connect, we will only read and retrieve information that we set in a cookie during an earlier visit to Programmatic Connect.
 
Most browsers are initially set to accept cookies. If you’d prefer, you can set yours to refuse cookies or to alert you when cookies are being sent. However, it is possible that some parts of Programmatic Connect will not function properly if you do so.
 
Device ID
 
A Device ID is a string of numbers and letters that identifies every individual smartphone or tablet in the world. The ID number itself is stored on the mobile device and it can be retrieved by any app that is downloaded and installed. Apps typically retrieve the ID to use it for identification when talking to servers. In the context of mobile advertising, a device ID will be one of two things depending on your operating system. Either is used as the identity which advertisers, marketers and other services will track when looking for a particular type of device: On iOS, a device ID is called the ‘Identity For Advertisers’ (IDFA, or IFA for short). On Android, the device ID is the GPS ADID (or Google Play Services ID for Android). A user is able to access their GPS ADID within the settings menu under ‘Google – Ads,’ as well as reset the ID, and opt-out of ad personalization too.
 
We use device id to identify mobile users to reveal certain user behavior (which can be aggregated to identify trends) but it also allows us to put users into cohorts based on understood identifiers such as geographic region, or device. We track a user’s Device ID to create a much clearer picture of who they are, and how they behave over time. Can easy to see whether that user looks at your ad, installs your app and then how they use the app. This is because you can track their ID through the process. Testing users for better understanding of a cohort (such as for creative, or ad optimization) also improves due to usage of unique user IDs.
 
We use device id to help us see which areas are popular and which are not. This helps us to improve and update Programmatic Connect based on such data as total number of users and pages viewed.
 
REPRESENTATIVES OF DECEASED USERS
 
If you are the fiduciary, representative or loved one of a deceased Programmatic Connect user, first of all please accept the sincere condolences of all of us at Programmatic Connect, LLC on your loss. The following procedures are applicable to the account of the deceased user.
 
All matters and things pertaining to Programmatic Connect accounts of a deceased user are governed by the provisions of Article 13-A of the New York Estates, Powers and Trusts Law (“EPTL”) any other conflicting law to the contrary notwithstanding and regardless of the location of the deceased user or his or her relatives or representatives. Some of the salient provisions of Article 13-A of the EPTL are summarized below. However, all of the applicable provisions of Article 13-A of the EPTL shall apply to all accounts of deceased users, whether or not summarized below. You and/or your attorney should be familiar with all applicable provisions of Article 13-A of the EPTL.
 
If you are the fiduciary of a deceased user and you wish to have us disclose the content of or terminate the account of a deceased user, you should do the following in compliance with the provisions of Article 13-A of the EPTL, send the following to the address below: (1) a written request for access to or termination of the deceased user’s account, (2) a certified copy of the deceased user’s death certificate, (3) a court certified copy of the document appointing the fiduciary or representative, (4) all information available to identify the account of the deceased user and (5) all information available to link the deceased user to the account to which access is requested.
 
Similar procedures apply in the case of a guardian or other fiduciary of an incompetent user. In all cases where the account user is alive or we have a reasonable basis to believe that the account user is still alive, we will use our best efforts to identify and notify the account user of the request.
 
Within 60 days of the receipt of all documentation required to complete your application, if we determine that your request is proper, we will grant the request. If we do not act within the sixty-day period, you may apply to court (see applicable sections of the Terms of Use and Privacy Policy as to which courts(s) have jurisdiction to hear your claim. Please note that, if we observe access to the account subsequent to the date of the application, we may deny your request. We will comply with the requirements of all lawful and proper court orders. If there is a direction by the original user of the account (whether under a Will, Trust or a procedure which we may, but are not obligated to establish), we will comply with such direction to the greatest extent possible under all applicable law. Programmatic Connect, LLC, its employees, officers, agents and owners shall be immune from any and all liability with respect to any and all acts or omissions done in good faith compliance with the provisions of Article 13-A of the New York EPTL.
 
DISPUTES
 
All disputes shall be governed by the laws of the State of New York, any conflict of laws rule to the contrary notwithstanding, to the greatest extent possible without violating any law. You consent to the confidential arbitration of any dispute, with such arbitration to be held in the City of New York before a three-judge panel in conformance with the rules of the American Arbitration Association. You consent to the binding effect of any such arbitration. You consent that the Supreme Court (or Surrogate’s Court, if appropriate) of the State of New York for the County of Queens and the United States District Court for the Eastern District of New York shall have exclusive jurisdiction of any action which you may bring. You consent that, to the greatest extent permissible by law, you will not bring or join any class action against Programmatic Connect or any owner or employee thereof.
 
 
CONTACT
 
If you have any questions or concerns about our Privacy Policy or its implementation, you may contact us at:
 
Attn: Policy Coordinator
Programmatic Connect, LLC
1847 62nd Street
Brooklyn, New York 11204
Telephone number: (347) 414-3149
Electronic mail address: sales@programmaticconnect.com
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