Privacy Policy

  1. Where This Privacy Policy Applies
  2. Information We Collect Via The Websites
  3. Information We Collect Via Data Services
  4. Our Use Of Cookies And Other Data Collection Technology
  5. How We Use Information Collected Via The Websites
  6. How We Use Information Collected Via Data Services
  7. How We Share Information
  8. How We Protect And Retain Information
  9. Your Choices About Your Personal Information
  10. Children’s Privacy
  11. Your California Privacy Rights
  12. International Users 
  13. Links To Other Websites And Website
  14. Updates to this Privacy Policy
  15. Questions?

PERSISTENT ID. PRIVACY POLICY

Effective Date: August 11, 2020

Welcome! Command Precision Inc. d/b/a Persistent.id (“Command Precision” or “we”) is committed to respecting your privacy.  Please read this Website Privacy Policy to learn how we collect and process personal information about you when you visit https://persistent.id or https://commandprecision.com/  (together, our “Website”) and how you can exercise your privacy rights.

WHERE THIS PRIVACY POLICY APPLIES

This Website Privacy Policy describes the information that Command Precision collects when you visit our Website.  To learn more about information we collect in the course of providing our data management, audience targeting and related services (“Services”), please see our Services Privacy Policy at https://persistent.id/policy/

INFORMATION WE COLLECT VIA THE WEBSITES

The information we collect depends on how and why you use the Website.  In general, we collect personal information from or about you for the purposes described in this Website Privacy Policy or for purposes that we explain to you when or before we collect your personal information. 

  • We collect the information that you provide to us. For example, if you submit an inquiry on the Website, Command Precision may collect your name, telephone number, email address and other information that you choose to give us to respond to the inquiry.
  • We automatically collect information about your use of the Website. We automatically collect certain information from your computer or mobile device when you use the Website.  Some of this automatically collected information is personal information under certain laws.  The information that we collect automatically includes:
    • Information about how your computer or device interacts with our Website, including the date, time, search requests and results, webpages accessed and links clicked.
    • Depending on the settings of your computer or mobile device, we also automatically collect: Internet Protocol (IP) address; MAC address; device make, model and operating system version; mobile network information; internet service provider; browser type and language; country and time zone in which the device is located; and metadata stored on the device.

 

This information is collected through cookies and other data collection technology, as described below.

We may collect information from other sources and combine it with information we collect from or about you on the Website.  When the combined information directly or indirectly identifies you, we treat it as personal information.

We also may collect information in other ways that are disclosed to you at the time information is collected from you or with your consent.

INFORMATION WE COLLECT VIA THE DATA SERVICES

We collect certain pseudonymous personal information when providing the Data Services, such as hashed email addresses, IP addresses, mobile advertising identifiers and a unique ID placed in an HTTP cookie (as described below).  We also may collect the domain and time stamp when consumers visit third-party websites, browser languages and types, device types and operating systems, IP addresses and similar data not directly identifying an individual person, all of which are used for targeted advertising and measurement use cases (“Web Traffic Data”). The sources of this data includes, publishers,  marketers, email service providers, web hosting companies, ad measurement companies, data brokers, and analytics companies. We also may collect information in other ways that are disclosed to you at the time information is collected from you or with your consent.

OUR USE OF COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

We use cookies, pixel tags (also known as web beacons or clear GIFs) and similar data collection technology on the Website.  

What are cookies and pixels?

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive.  A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.  A cookie also may contain information about your computer, such as settings, browsing history and activities conducted while using the website.

“Pixels” (also known as web beacons) are transparent images that are used in collecting information about website usage across websites and over time.  

Cookies that Command Precision sets on the Website are called first-party cookies.  They enable us to track how often users are using the Website and the specific pages visited and other user preferences and actions.  Cookies set by any other party are called third-party cookies.  Third-party cookies enable third-party features or functionality on or through the Website, such as analytics, marketing automation and customer support.  The parties that set third-party cookies can recognize your computer both when it visits the Website and also when it visits certain other websites.

We also use Google Analytics on the Website, which is a Google service that collects aggregate information about use of the Website and reports website trends.  Google Analytics does not directly identify individual users.  You can learn about Google’s practices at https://safety.google/privacy/privacy-controls.

You can refuse to use cookies by turning them off in your browser.  Most browsers accept cookies automatically but allow you to disable them.  You can reset your browser to refuse all cookies or to indicate when a cookie is being sent.  You do not need to have cookies turned on to use the Website, although some features of the Website may not work properly without cookies.  You also can opt-out of certain cookies using the following link: http://optout.networkadvertising.org/?c=1.  To learn more about cookies generally, visit www.allaboutcookies.org and http://optout.aboutads.info/?c=2&lang=EN.

 

Our Policy On Do Not Track Signals.  

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Command Precision, do not respond to DNT signals. 

HOW WE USE INFORMATION COLLECTED VIA THE WEBSITES

We use information collected on the Website to operate the Website, including:

To communicate with you

  • Respond to your requests or provide you with information that you request
  • Communicate with you about services that we think may interest you or updates to our Services

 

To improve the Website

  • Maintain our Website
  • Analyze users’ behavior to improve the Website

 

To prevent, detect and fight fraud or other illegal or unauthorized activities

  • Prevent, detect, identify, investigate, respond and protect against potential or actual claims, liabilities, prohibited behavior and criminal activity

 

We also may use information collected through the Website to comply with legal requirements or to enforce or exercise our rights.

HOW WE USE INFORMATION COLLECTED VIA THE DATA SERVICES

We use Match Data to help our customers better target their online advertising, and to better understand how their current and prospective customers use the Internet. We also may use information in other ways that are disclosed to you at the time information is collected from you or with your consent. We may also use information collected via the Websites or Data Services comply with legal requirements, to assist our security efforts, to fight illegal activity or to enforce or exercise our rights.

HOW WE SHARE INFORMATION

  • Service Providers. We disclose information collected through the Website with third-party service providers.  We require all of our service providers to adhere to confidentiality and data protection obligations that are consistent with this Website Privacy Policy.  Our service providers work on our behalf and are only permitted to use data as directed by us.

 

The third-party service providers used by Command Precision include: a) cloud computer, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) outsourced computer programmers helping ensure our systems are operating properly and e) auditing, debugging and security vendors.

 

  • Promotional partners and affiliates. We may collect and aggregate information about users of the Website (such as how many persons visited a particular page) and share it with our promotional partners and affiliates but this aggregated information does not include information that directly identifies any individual person.

 

We also share information that we collect:

  • For corporate transactions. We may transfer information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
  • When required by law. Applicable law may require us and our service providers to disclose information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government or regulatory investigation or request or similar requirements; or (ii) necessary for the prevention or detection of crime (subject to applicable law).
  • To enforce legal rights. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing.

 

We may ask for your consent to share information collected through the Website with third parties in ways not described in this Website Privacy Policy.  When we do, we will make clear why we want to share the information. 

HOW WE PROTECT AND RETAIN INFORMATION

We use physical, technical and organizational measures designed to protect information against unauthorized access, theft and loss.  We restrict access to information to those employees who need to know that information to perform their job functions.  Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure.  Any transmission of your information is at your own risk.  Please use appropriate security measures to protect your personal information.  If you have questions or concerns about our security practices, please contact us at [email protected]  We will retain your information for the period necessary to fulfill the purposes outlined in this Website Privacy Policy, unless a longer retention period is required or permitted by law.

YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

Please contact us at [email protected] if you would like to opt-out of our sale of personal information or if you’d like to review, correct or delete personal information about you collected by us if and when these rights are provided to you by law.  In your request, please make clear the personal information about you to which your request relates and the actions you would like us to take.  For your protection, we will attempt to verify your identity before fulfilling your request.  Please note that we often need to retain certain information for recordkeeping purposes and our databases and other records may have residual information that we will not remove.  We also may not allow you to review, correct or delete certain information for legal, security or other reasons.  If at any time you believe that we have not adhered to this Website Privacy Policy, please let us know.  We will use good faith efforts to determine and correct the problem.

 

IF YOU ARE LOCATED IN ANY MEMBER STATE THAT IS PART OF THE EUROPEAN ECONOMIC AREA OR ANY MEMBER STATE THAT HAS ADOPTED THE GENERAL DATA PROTECTION REGULATION, YOU ARE NOT PERMITTED TO PROVIDE PERSONAL DATA TO US.

 

 

OTHERWISE, IF YOU ARE LOCATED IN A JURISDICTION WITH DATA PROTECTION LAWS THAT OFFER YOU PRIVACY RIGHTS NOT DESCRIBED IN THIS PRIVACY POLICY, PLEASE CONTACT US AT [email protected].  We respect your privacy rights and will do our best to accommodate your requests.

CHILDREN’S PRIVACY

Command Precision does not knowingly collect personal information from children under age 13.  If we learn that a minor has provided us with information, we delete the minor’s personal information from our records.

YOUR CALIFORNIA PRIVACY RIGHTS

This California Privacy Rights Notice (“California Privacy Notice”) applies to Command Precision’s processing of personal information (as defined below) of residents of the State of California as required by the California Consumer Privacy Act of 2018 (“CCPA”).  If you are a California Consumer (as defined below), this California Privacy Notice explains your privacy rights, how and why we collect and process your personal information and how you can exercise your privacy rights. 

 

Definitions for this California Privacy Notice

  • CCPA defines California residents as “consumers” and we refer to them in this California Privacy Notice as “California Consumers.”
  • The term “business” in the CCPA means a person or entity that operates in California and collects (or has collected) personal information and determines how and why that personal information is used. Generally, Command Precision is the “business” for information it collects on the Website or acquires from third parties.
  • Under the CCPA “personal information” means information that identifies, relates to, describes or could reasonably be linked, directly or indirectly, with a particular California Consumer, household or device.
  • The term “service provider” in the CCPA means a person or entity that receives personal information from a business and can only use that personal information to perform services for the business or to build and improve its products and services, detect and protect against data security incidents and other limited purposes. Command Precision may be a “service provider” for information it collects on behalf of certain clients.

 

Your California Consumer Privacy Rights

If you are a California Consumer, you have these privacy rights with respect to your personal information:

  • You have the right to know the categories of personal information directly or indirectly collected from you in the past year, the purpose for collecting your personal information and how your personal information is used. The personal information that Command Precision collects when acting as a business and why we collect it is set forth in the table below.  The sources from which we collect personal information are described above.
  • You have the right to know whether your personal information was disclosed for a business purpose and to whom or what entity the personal information was disclosed.
  • You have the right to request deletion of certain personal information collected from you.
  • You have the right to opt out of sale of your personal information when a business sells your personal information.
    • Sharing your personal information with our service providers is not a sale of your personal information because we make sure that our service providers are contractually obligated to use the personal information only to provide services to us and not to sell it.
  • You have the right to equal treatment after you exercise any of these rights. That is, we cannot treat you differently for exercising any of these rights unless we demonstrate that the value of the personal information that you provide to us is reasonably related to the difference in price or service that we offer.

 

We currently do not offer financial incentives or price or service differences in exchange for personal information.  If we  do, we will notify you in advance before collecting your personal information for this purpose and explain how you can opt in to the financial incentive or price or service difference.

 

Personal Information Collected from California Consumers

The following table lists categories of personal information that generally match the categories in the definition of personal information in the CCPA.  We indicate for each listed category the specific types of personal information in the category that we have collected from California Consumers within the past 12 months in our role as a business and why we collect it. 

CCPA Category of Personal Information

Personal Information in CCPA Category that Command Precision Collected from California Consumers in Past 12 Months

Why Command Precision collects this Personal Information

A. Identifiers

Depending on how you use our Website, we collect name, alias, business postal address, unique personal identifier, unique online identifiers, Internet Protocol address, cookie ID, advertising ID, computer and mobile device identifiers, and RFID numbers.

 

 

·       To provide and promote our Services.

·       To respond to requests and send you information and updates about our Services that we think will interest you.

·       To obtain your feedback regarding our Services so that we can improve our features and develop new ones.

·       Prevent, detect, identify, investigate, respond and protect against potential or actual claims, liabilities, prohibited behavior and criminal activity.

·       When you otherwise choose to give it to us.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Depending on how you use our Website, we may collect name, signature, business address and business telephone number from representatives of customers and prospective customers. We do not collect social security numbers or physical characteristics or descriptions. 

For the reasons described in Row A above. 

C. Protected classification characteristics under California or federal law

None

N/A

D. Commercial information

Records of services purchased.

To operate and promote our Services.

E. Biometric information

None

N/A

F. Internet or other similar network activity

Browsing history, search history, information about a California Consumer’s interaction with a website, application or advertisement.

·       To provide and promote our Services.

·       To obtain your feedback regarding our Services so that we can improve our features and develop new ones.

·       To understand more about you so that we can better target advertising to you. 

·       Prevent, detect, identify, investigate, respond and protect against potential or actual claims, liabilities, prohibited behavior and criminal activity.

G. Geolocation data

We may determine general physical location or movements from IP address. 

To understand more about you so that we can better target advertising to you. 

 

H. Audio, electronic, visual, thermal, olfactory or similar information.

None

N/A

I. Professional or employment-related information

None

N/A

J. Non-public education information per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)(“FERPA”))

None

N/A

K. Inferences drawn from other categories (A – J above) to create a profile about a consumer

We collect information about your browsing history, including IP address, web pages that you visit, the time and date, and whether or not you clicked on various advertisements when you visit the Website or any Customer Site.

To customize your experience with the Website, to improve the Website, to develop new services and to analyze your actual or likely preferences through the personal information we collect and process as described above.

HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

To submit a request to exercise your privacy rights:

  • Send an email to [email protected] with the subject line “California Privacy Rights Request.”
  • Call us via our toll-free telephone number at 1-888-367-6911.
  • To opt-out of sale of your personal information, please click the “DO NOT SELL” button at the bottom of https://persistent.id.

 

Please note:

  • We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
  • We may not honor all or part of your request. For example, certain information we collect may be exempt from this California Privacy Notice, such as public information made available by a government entity or information covered by another privacy law.  Please also note that personal information collected in many types of B2B transactions is exempt from most of CCPA’s requirements until January 1, 2021.  If we do not honor your request, we will explain why when we respond to you.

 

If you are a California resident, California’s Civil Code Section 1798.83 permits you to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year.  If you would like to exercise your rights under this California law, please send a written request to the email address or postal address below or call us at the telephone number below.  Within 30 days of receiving your request, we will provide you with the relevant information.

 

Our Address:

Persistent.id

100 Summit Drive, Suite 100

Burlington, Massachusetts 01803

Email: [email protected] with a subject line of “California Privacy”.

 

INTERNATIONAL USERS

The Website is controlled, operated and administered by Command Precision from its offices in the United States.  We make no representation that any content available through the Website is appropriate or available for use outside the United States.  You are prohibited from accessing the Website or its content from territories where such access is illegal.  You may not use the Website in violation of U.S. export laws and regulations.  If you access the Website from a location outside the United States, you are responsible for compliance with all applicable laws.  If you are located in any member state that is part of the European Economic Area or any member state that has adopted the General Data Protection Regulation, you are not permitted to provide personal data to us.

LINKS TO OTHER WEBSITES AND WEBSITE

The Website may include links to third-party websites that are not operated by us.  When you use a third-party website, you are subject to its privacy practices and policies, not ours.  This Website Privacy Policy does not apply to any information that you provide to websites that are not operated by Command Precision. 

UPDATES TO THIS PRIVACY POLICY

We may update this Website Privacy Policy from time to time in response to changing legal, technical or business developments.  When we update our Website Privacy Policy, we will post the updated version and change the Effective Date above.  We also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Website Privacy Policy before it is effective.  If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Website Privacy Policy applies to you.

QUESTIONS?

If you have any questions about this Privacy Policy or the Websites, please contact us at [email protected]

Persistent.id
100 Summit Drive, Suite 100
Burlington, Massachusetts 01803

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