Effective as of May 25, 2018
This Policy applies to our websites, products, emails we send, as well as the information we collect when you interact with us through social media or other websites and online services. It does not apply to non-Intertrust websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.
2. What Information We Collect
Information That You Provide
When you become or express interest in becoming a client of Intertrust, we ask you to provide certain information to allow us to communicate with you and provide customized products and services. This information typically includes your name or email address, demographic information (your age, gender, ZIP code or similar information), business information (including your job title, employer, and business contact information), and certain information about your interests and preferences. We will also collect payment information (typically, credit card account information) if you choose to purchase products or services through our websites.
The Services may also provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, suggestions, indications of interest in the content or other content, (collectively, “User Content”). When you create User Content in a Community Forum, that content is displayed publicly. Your name, along with any information you have disclosed in your profile, will be accessible by other users of the forum as well as the general public.
Information Third Parties Provide About You
We may receive information about you from third parties. For example, we may supplement the information we collect with outside records in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes.
Information We Collect Automatically
When you interact with the Services, as either a client, direct visitor to our website, or indirect user through a product employed by a third-party application, certain information about your use of our Services is automatically collected. This information includes, as applicable, the IP address or other unique identifier for any computer, mobile phone, or other device used to access our Services, the browser and operating system you are using, the URL or advertisement that referred you to our Services, any search terms you entered into a search engine that led you to our Services, the areas within our Services that you visited, and the time of day you visited our Services, among other information.
- Essential operation: These cookies are necessary to allow us to operate the Intertrust website as you have requested. For example, they let us recognize what type of customer you are and then provide you with services accordingly.
- Performance/Analytics: We use these cookies to analyze how the Intertrust websites are accessed, used or are performing. We use this information to maintain, operate and continually improve the Intertrust websites. We may also obtain information from our e-mail newsletters, to learn whether you opened or forwarded the newsletter or clicked on any of the content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information that you find interesting.
- Functional: These cookies let us operate certain functions of the Intertrust website in line with the choices you make
- Advertising: Third parties, including Google, Facebook, and other social media platforms, may use tracking technologies on our website to collect or receive information from the Intertrust websites and elsewhere on the internet and use that information to provide measurement services and target ads.
You may refuse to accept cookies, or remove cookies, by editing the privacy and security settings of your browser. For further information, see Your Options below.
3. How We Use Information We Collect
We may use information collected through our Services, including your personal information and usage information, to:
- Communicate with you, including to respond to your inquiries and fulfill your requests;
- Administer and develop our business relationship with you and the company for which you work;
- Provide you with more relevant content in email bulletins to which you may be subscribed;
- Provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;
- Provide and improve our products and services;
- Provide services on behalf of our clients who employ specific products, as described in Section 11
- Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
4. How We Share Information with Third Parties
We may share the information collected via our Services with companies who work on our behalf to help us provide and support the Services and our products and services. This includes allowing third parties to use tracking technologies to collect information as outlined above.
We may transfer and disclose information about you to third parties in order to comply with a legal obligation; when we believe that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms & Conditions or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Intertrust, users of the Services, or others.
Intertrust may share your information about you with its subsidiaries and affiliates, primarily for business and operational purposes. In the event Intertrust goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process, your information will likely be among the assets transferred.
5. Your Options Regarding Interest-Based Advertising
Interest-based advertising is the collection of information across different websites and/or different devices for the purpose of tailoring advertising based on preferences or interests know or inferred from the information collected.
Intertrust does not serve advertising on its website, but we partner with third parties to use the information you make available to us when you interact with our Services to provide you with advertising that is more relevant to you after you leave our Services. You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.
Your browser or device may include “Do Not Track” functionality. At this time, Intertrust does not respond to browser “Do Not Track” signals.
Intertrust takes commercially reasonable steps to help protect and secure the information it collects and stores about its users. However, please remember that no data storage or data transmission is guaranteed to be 100% secure. Thus, while we strive to protect your Personal Information, Intertrust cannot ensure or warrant the security of any information you transmit to us. You use our services and provide us with your information at your own risk.
7. Consent to transfer
If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.
8. Users in the European Economic Area (EEA) and Switzerland
If you are a resident of the EEA or Switzerland, the following information applies.
Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Services. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.
Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Upon the start of enforcement of the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.
Individual Rights: If you are a resident of the EEA or Switzerland, you are entitled to the following rights once the GDPR becomes effective. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.
- You have the right to have your data erased from our Services if the data are no longer necessary for the purpose for which they were collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
- The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
9. California Residents – Your California Privacy Rights
Residents of the State of California have the right to request information regarding third parties to whom a company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please send an email to firstname.lastname@example.org or write to: Intertrust Technologies Corporation, Attn: Legal Department, 920 Stewart Drive, Suite 100, Sunnyvale, CA 94085. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing and included name, street address, city, state, and ZIP code.
10. Contact Us
Intertrust Technologies Corporation
Attn: Data Protection Officer
920 Stewart Drive, Suite 100
Sunnyvale, CA 94085
You can also contact our EU representative
Intertrust Technologies Corporation
Attn: Data Protection Officer
405 Kings Road
SW10 0BB, United Kingdom
11. Product-Specific Details:
11.1 Expressplay, Kiora, and Personagraph
Intertrust offers a number of tools that facilitate the delivery of content such as media and advertising through mobile applications and websites operated by its clients. These tools include the ExpressPlay line, Kiora, and Personagraph. Some of these tools are used to manage digital rights and authenticate the permissions of the end-user to view copyrighted material; others are used in relation to delivering advertising while an end-user is engaged with a client’s product.
Intertrust supports the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (“DAA”). We understand that you may wish to opt-out of our use of information about you or your devices to provide targeted advertising services to our clients. For more information on your options regarding interest-based advertising, please see Section 5 above.
When you use Intertrust’s Kabuto service, you may choose to allow Intertrust to collect information from your contacts files on services such as Outlook, Google, Facebook, and LinkedIn. If you access the Service on your mobile device, we may, with your permission, collect information regarding contacts stored on your device. We use this information in connection with your account to help you to email invitations to those contacts on your behalf at your request. We also allow you to provide the email addresses of other individuals for the purpose of file sharing or access.