Effective Date: 18 February 2020
Last Revised: 18 February 2020

 

This Privacy Notice applies to iTraffic Center, Inc. ("ITC") and Websites offered by ITC, including without limitation Cash Clubhouse (www.cashclubhouse.com) and our Services (as defined below). This Privacy Notice defines how ITC collects, stores, uses and discloses your Personal Data (as defined below). ITC will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.  ITC is headquartered in Potomac, Maryland with offices in the US.  This Privacy Notice defines how ITC collects, stores, uses and discloses your "personal data" or "personal information" (as defined below). ITC will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Notice.

 

This privacy notice constitutes a binding agreement between you and ITC. Your use of our website or services, or your participation in research, constitutes your consent to the terms of this privacy notice.

 

IF YOU DO NOT WISH TO HAVE US COLLECT, USE AND SHARE INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE, PLEASE DO NOT USE OUR SERVICES.

 

WE PROTECT YOUR PRIVACY

 

This privacy notice constitutes a binding agreement between you and ITC. Your use of our website or services, or your participation in research, constitutes your consent to the terms of this privacy notice.

 

ITC is strongly committed to protecting the privacy and security of  "personal data" or "personal information" (referred to in this Privacy Notice as "Personal Data") and conforms its privacy and security practices to applicable laws, and regulations, including, without limitation, the California Consumer Privacy Act (“CCPA”) and the General Data Protection Regulation (“GDPR”).

 

WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

 

As used in this Notice, Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household. Personal Data includes information such as real names, postal addresses, email addresses, and social security numbers.

 

Personal Data may also include unique identifiers, IP addresses, biometric information, internet or other network activity (such as browsing history, search history, etc.), geolocation data, audio/visual data, and even inferences which may be drawn from any of the above to create a profile about a data subject or consumer.

 

We may collect Personal Data for the purpose of offering you our Services market research, as expressly stated and agreed to by you, and as otherwise provided in this Privacy Notice.

 

Based on your use of our Websites and our Services,  in the previous 12 months, we may have collected, used, and shared Personal Data as described below:

 

  • Member names, email addresses, postal addresses, telephone phone numbers, date of birth

  • IP addresses, browser fingerprints, device id, unique identifiers, cookies, geolocation data, web beacons

  • Demographic data, such as age, gender, race/ethnicity, parental status, marital status, postal code, income and education levels

  • Information collected by our systems and stored in log files, including Internet Protocol (IP) address, browser type, browser language, the date and time of your requests, operating system, referring/exiting pages, clickstream data

  • Browsing information, such as date and time you visited our website(s), number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or research programs

 

Third-Party Links

Our Websites and Services contain links to other websites and other third-party provided goods and services that we do not own, operate nor control. In addition, because aspects of our Websites and Services include third-party offers ("Offers") for goods, services and the like, third parties may collect your information based on your interaction with those Offers. Third-party privacy practices are not covered by this Privacy Notice, and we are not responsible for the privacy practices of such third parties. We encourage our users to be aware of and to read the privacy statements and similar disclosures of any third-party website that collect personally identifiable information before using or disclosing any personally identifiable information to such website.

 

Advertising Networks and Analytics Companies

We may allow other companies, commonly called third-party ad servers or advertising networks (collectively, “Ad Networks”), to display advertisements on our Websites and our Services. These advertisements may be based on your interests as reflected in your use of our Websites and our Services, as well as your use of other websites and services. Some of these Ad Networks may place a persistent cookie or other similar technology on your computer, mobile device and other devices you use (collectively, “Device(s)”), allowing them to recognize you and/or your Device each time they send you an online advertisement.  In this way, Ad Networks may compile information about where you see their advertisements online and determine which ads you click on, so that we and they may provide you with Offers believed to be of most interest to you. We do not have access to or control over the cookies or other similar technologies that may be placed by these parties on your Device, nor do we have responsibility for these parties’ privacy policies or information collection practices. Likewise, we may also work with consumer data resellers that buy and/or sell information to other companies for multiple purposes including offering products and services that may interest you, and we use certain third-party analytics providers to help us understand how you use our Websites and our Services, and these companies may set their own cookies and similar technologies on your Device. For example, we use Google Analytics to track visitors’ activity on our website. Google Analytics and similar third-party analytics providers use web browsing data and other data analysis to improve their own products. These and other service providers may collect information about you, including but not limited to your online activities over time and across different websites and services, when you use our Websites and our Services, or other online websites and services. Each of these third parties has its own privacy policy that may differ from this Privacy Notice.   We may share your Personal Data and other information with our service providers for the purpose of making it easier for you to sign up for their Offers, validating your communications or transactions with them, authenticating and/or validating your identification, crediting you with any earned rewards, and for our business purposes. Additionally, we may share information with our service providers to assist us in delivering Offers to you, both on our Websites and our Services and elsewhere, and for our business purposes.

 

SENSITIVE INFORMATION

 

From time to time ITC may collect "sensitive personal data" or "sensitive personal information" (referred to in this Privacy Notice as "Sensitive Personal Data") which, depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If ITC collects your Sensitive Personal Data, ITC will always obtain your explicit consent.

 

OTHER USES AND SHARING OF INFORMATION

 

In addition to the uses listed in the table above, we may also use and share your Personal Data:

 

  • in connection with the request or requirement of any lawful request by public authorities;

  • to meet national security or law enforcement requirements;

  • in connection with the sale, assignment, or other transfer of our business, in which case ITC will make commercially reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Notice;

  • if ITC believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity; or

  • as otherwise authorized by you.

 

If a statutory condition applies allowing (ITC to process your Personal Data and you withdraw consent to process your Personal Data this will not necessarily mean that ITC will cease to process your Personal Data as it may, for example, be under a statutory duty to continue to process your Personal Data for some purposes, e.g. to keep copies of commercial transactions for a minimum of seven years.

 

Please note that receiving email communications may be a requirement of your participation in our surveys or research programs. You can opt out from receiving these emails by unsubscribing from the survey or research program.

 

ADDITIONAL INFORMATION ON INFORMATION COLLECTED THROUGH AUTOMATED MEANS

 

Cookies

Cookies are small text files stored on your computer by a website that assigns a numerical user ID and stores certain information about your online browsing. We may use cookies on our survey site to help us recognize you as a prior user.

 

If you wish, you can adjust your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies, however doing so may negatively impact your user experience when participating in one of our surveys or other research programs.

 

Web Beacons

A web beacon (also known as a tag, clear gif or 1x1 pixel), consists of a small string of code that is embedded within a web page or email. There may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

 

We may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to users, to improve the quality of the emails that we send and to query users who do not open our emails as to whether they wish to continue receiving them. The web beacon is deleted when you delete the email.

If you would prefer not to have web beacons in the emails that you receive, you should adjust your email program to receive messages in plain text rather than HTML. It is also possible to detect and control web beacons that are present on web pages by downloading a plug-in for your browser.

 

Log Files

ITC may use logging throughout your survey-taking and research program experiences. When you access any of these services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.

 

Geo-Location Data

ITC may collect geo-location information from your computer or device. ITC may use your geo-location data for fraud prevention or for market research purposes, including but not limited to advertising research or other tracking-based market research activities. ITC will obtain your consent if ITC collects or uses your geo-location information.

 

Digital Fingerprinting

ITC may use digital fingerprinting technology, also known as “machine identification” technology (“Digital Fingerprinting”), to gather certain data about you and/or your computer. This data may include Personal Data an Internet Protocol (IP) address, as well as other data such as a computer operating system or browser version number. This technology creates a unique computer identifier (“ID”) that may be used to identify and track your participation in a survey or other research program and limit participation.

 

ITC may utilize Digital Fingerprinting technology to assist our clients in ensuring the integrity of survey results by enabling us to authenticate users and to help ensure users participate in surveys no more than the maximum allowable participation. In furtherance of ITC’s efforts to assist its clients in protecting and ensuring the integrity of survey results, ITC may: (a) link or associate an ID to an individual or to Personal Data of an individual; (b) share an ID with ITC’s clients and/or sample or panel providers; and/or (c) receive or obtain a unique identifier that is linked to an identified or identifiable individual. Any unique identifier(s) received or obtained by ITC that are linked to an identified or identifiable individual will be protected in accordance with this Privacy Notice.

 

INFORMATION FOR CALIFORNIA RESIDENTS

 

Personal Data We Sell or Disclose

CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”

 

Under this definition, and the CCPA’s broad definition of “personal information” (again referred to in this Privacy Notice as "Personal Data"), we may “sell personal information” about you to our clients or other collaboration partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.

 

Categories of information we’ve “sold” in the previous 12 months include: demographic data, such as age, sex, race/ethnicity, parental status, marital status, postal code, income and education levels; participant photos, video, and audio; and other anonymized or aggregated information from research and survey results.

 

Categories of information we’ve otherwise disclosed for a business or commercial purpose (for example, for confidential use by our service providers) in the previous 12 months include: the above categories of information we’ve “sold,” as well as log files, browser type, operating system, and other machine information.

 

When you participate in one of our surveys or research programs, the information you provide or is otherwise collected may be combined with the information of other participants and reported as part of aggregate results. Additionally, the information you provide or is otherwise collected may be used in statistical modeling to better understand trends among the general population. When such statistical modeling is performed, your Personal Data will not be released.

 

We will not make your Personal Data available to any third party without your consent or required by law, as further specified below.

 

Notice to California Residents

If you are a California resident, you also have the following special rights:

 

  • Your Right to “Know” and to Request Deletion

 

You have the right to know the categories and specific pieces of Personal Data we have collected about you.

 

You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.

 

You have the right to request deletion of personal information we’ve collected or maintain.

 

To exercise these rights contact us at [toll-free number] or by filling out the following webform. We may ask you to provide additional information, such as name and email address in order to verify who is making the request.

 

Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

 

  • Your Right to Opt Out of the “Sale” of Your Information

 

You have the right to opt out of the sale of your personal information. For more information on how to opt out, please click here.

 

  • Your Right to Non-Discrimination

 

You have the right not to receive discriminatory treatment by ITC for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that we are in the business of providing market research services to our clients, and any financial incentives we offer to facilitate that goal may be rewarded only if the applicable survey, research project or study is fully and properly completed by the respondent, in the sole discretion of ITC.

 

  • Your Right to Use an Authorized Agent

 

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.

 

  • Verification Process

 

If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.  

 

  • Notice of Financial Incentive

 

ITC may offer opportunities for you to earn money and rewards by completing survey or research programs. Participation in these offerings may require you to provide Personal Data. For more information about how to opt in to these offerings, or about how to opt out once you have opted in, see the notices and official rules accompanying these incentives.

INFORMATION FOR CITIZENS OF THE EU AND SWITZERLAND ABOUT CROSS-BORDER TRANSFERS

 

ITC complies with the Principles of EU-US and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries and Switzerland.    To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

 

In compliance with the EU-US and Swiss-US Privacy Shield Principles, ITC commits to resolve complaints about your privacy and our collection or use of your Personal Data.  European Union and Swiss individuals with inquiries or complaints regarding this privacy notice should first contact ITC at:

 

ITC

9218 Winterset

Potomac, MD 20854

Attn:  Privacy Compliance Officer

 

Notice to EU Residents

You have the right to review, correct, or delete your Personal Data. Specifically:

 

•    Right of access

 

You have the right to obtain confirmation and information about the processing of your Personal Data.

 

•    Right to rectification

 

You have the right to have any inaccuracies about your Personal Data corrected

 

•    Right to erasure

 

You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing)

 

•    Right to restriction of data processing

 

You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honoring your request, ITC's access your Personal Data will be limited)

 

•    Right to data portability

 

You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)

 

You may access information we collect from or about you in order to review, correct, or delete such information by:

 

Sending an email request to: privacy@itrafficcenter.com,

 

Regular mail to:

 

ITC

9218 Winterset

Potomac, MD 20854

Attn:  Privacy Compliance Officer

 

BUSINESS TRANSITIONS

 

In the event the ITC (or any of its Affiliates) goes through a business transition, such as a merger, consolidation, restructuring, acquisition by another company, sale or assignment of rights or assets (or a portion thereof), or other company change, we may transfer users’ information, including Personal Data, and other business data in connection with that business transition (e.g., to a subsequent owner, co-owner, or operator of any of our Websites or our Services, or any affiliates and agents, service providers, or partners of the foregoing), including during the course of any due diligence process.

 

DO WE COLLECT INFORMATION FROM CHILDREN?

 

We do not want to or knowingly attempt to solicit or receive Personal Data from children or any individual under the age of 18.  If ITC becomes aware that ITC has inadvertently collected Personal Data from a child or any individual under the age of 18, ITC will delete such Personal Data from our database.

 

WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO HELP ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION?

 

The security of your Personal Data is very important to us. We have put in place reasonable physical, electronic, and administrative procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.

 

We cannot guarantee that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers, and your use of our services demonstrates your assumption of this risk.

 

 

LINKS TO OTHER WEBSITES

 

This website may contain links to other websites. ITC is not responsible for the privacy practices or the content of such websites. To ensure the protection of your privacy, always review the privacy notice of the websites you visit by linking from this website.

 

CLASS ACTION WAIVER

 

Any arbitration or court trial, related to any claim under this Privacy Notice, whether before a judge or jury or pursuant to judicial reference, will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS NOTICE. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator. THIS CLASS ACTION WAIVER IS VOID WHERE LIMITED OR PROHIBITED BY LAW.

 

WHO CAN I CONTACT WITH QUESTIONS OR COMPLAINTS ABOUT THIS PRIVACY NOTICE?

 

If you have any questions or complaints regarding ITC’s privacy practices and/or this Privacy Notice or want to communicate an opt-out request to ITC, please contact us by:

 

Sending an email request to: privacy@itrafficcenter.com

 

Regular mail to:

 

ITC

9218 Winterset

Potomac, MD 20854

Attn:  Privacy Compliance Officer

 

ITC's Legal Department is responsible for the organization’s compliance with this Privacy Notice.

 

ACCEPTANCE AND UPDATES TO THIS PRIVACY NOTICE

 

By using the website, you signify your acceptance of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not use this website.

 

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this Privacy Notice at any time. We encourage you to refer to this Privacy Notice on an ongoing basis. Your continued use of the website following the posting of changes will mean that you signify your acceptance to those changes.

 

This Privacy Notice is current as of the “last revised” date which appears at the top of this page. We will treat Personal Data in a manner consistent with the Privacy Notice under which it was collected, unless we have your consent to treat it differently. By using this website following any Privacy Notice change, you freely and specifically give us your consent to collect, use, transfer and disclose your Personal Data in the manner specified.