Numerator Privacy Policy 

Last modified: January 1, 2020 

Introduction

This Privacy Policy applies to your use of http://www.numerator.com (collectively known as, “Numerator”, “We”, “Us”, or “Our”) which are owned and operated by Market Track, LLC d/b/a Numerator.  This Privacy Policy describes how we collect, use, share and secure the personal information we may collect when you visit the Numerator site.  It also describes your choices regarding use, access, deletion, and correction of your personal information.  We will review the notice regularly and publish updates as required by law, statute and/or regulation where your rights will be no less than what is required by law, statute, and/or regulation. 

Numerator provides products and services to our clients (such as agencies, brands, manufacturers and retailers) to help them better understand consumer behavior and the markets in which they do business. 

Please note that:

  • All the information set out in this Policy may not apply to you.  Our interactions with you, and the choices you make with regard to how you use Numerator, will determine which portions of the Policy apply to you and your personal information.  Wherever we provide examples of information in this Privacy Policy, the examples are not intended to be an exhaustive list;
  • When you share personal information with us or when we collect personal information about you, we will use it in line with this Privacy Policy. Please read this Policy carefully. If you have questions or concerns about your personal information, please contact us at privacy@numerator.com; and
  • This Policy does not cover our clients’ use of your personal information outside of the products and services we may provide them. We are not responsible for the privacy practices of our clients.  Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by third parties.  Any such participation will be subject to the relevant third party's terms and conditions.

PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT 

We may collect your information in several ways, including the following:

  • Information You Provide Us Directly.  We collect personally identifiable which you choose to provide us directly.
  • Information We May Collect Through Automated Technologies.  We may collect personal information through the use of cookies, tags, web beacons and other technologies.  We may also collect unique device identifiers and may collect geolocation information if we have the appropriate legal basis to do so.  
  • Information We Receive from Our Clients.  We may collect information from our clients who provides your information to us so that you (for the benefit of the client) are able to login to our sites and/or services.
  • Information We May Receive from Other Parties.  We may combine the information we receive from you with information we receive from other sources.

We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so under applicable law. The chart below summarizes when we collect personal information, the types of personal information we collect and how we use the personal information.

HOW WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES 

  • We share information with third parties for advertising purposes as described below under “Cookies and Similar Technologies”.
  • We may share your personal information with third party service providers or data processors that help manage our business and deliver services, for example, IT service providers who help manage our IT and back office systems or administer our sites and services. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us. 
  • We may share information with government organizations and agencies, law enforcement and regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
  • We may share in aggregate, statistical form, non-personal information regarding the visitors to our sites with our partners, affiliates or advertisers.
  • If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.

In addition to the above, we may share personal information about you with others to the extent you consent to such sharing.

TRANSFERRING PERSONAL INFORMATION GLOBALLY

International data transfers

We may transfer to and store the personal information we collect in countries other than the country in which the personal information was originally collected, including countries outside the EU/EEA, in accordance with applicable law. Those countries may not have the same data protection laws as the country in which the personal information was provided. For example, your personal information may be stored in the United States and your personal information may be transferred to or accessed by Market Track, LLC, its affiliates and service providers in the United States.  When we transfer personal information to other countries, we will protect the personal information as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside the EU/EEA. This includes by entering into the European Commission’s EU Standard Contractual Clauses with the data importer, or ensuring that the data importer has certified to the EU-U.S. Privacy Shield Framework (as discussed below), or has implemented Binding Corporate Rules. To obtain a copy of the safeguards we have put in place, please contact us as indicated below.

EU-U.S. Privacy Shield

Market Track, LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Market Track, LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov

Market Track, LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  Market Track, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Market Track, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.   In certain situations, Market Track, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

COOKIES AND SIMILAR TECHNOLOGIES

When you visit our website or click on a banner advertisement, we and our partners, affiliates, or analytics or service providers may send one or more cookies or similar technologies to your computer or other device to collect information that helps us improve the quality of site and service and the online experience of our visitors and users. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained below:

  • Cookies and other data collection technologies: We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage:
    • Required cookies: These cookies are necessary to enable the basic features of our site to function, such as allowing images to load or allowing you to select your cookie preferences.
    • Functional cookies: These cookies allow us to analyze your use of our site to evaluate and improve our performance. They may also be used to provide a better customer experience on our site. For example, remembering your log-in details or providing us information about how our site is used.
    • Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

We are committed to earning and keeping your trust. We understand the need for your personal information to remain secure and private, and we have implemented security practices and procedures designed to safeguard your information.

Please remember that you also play a valuable part in data security. You should never share your Account password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using our website(s), you should log out of your Account and exit your browser so that no unauthorized persons can use our website under your name or Account.  If you have any questions about the security of your personal information, you can contact us at privacy@numerator.com.  

We will retain your information for as long as your account is active or as needed to provide you services and to fulfill the purposes for which the data was collected.  We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. 

DIRECT MARKETING

How we use personal information to keep you up to date with our services 

We may use personal information to let you know about our services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activities with you.

We also work with carefully selected third parties, such as promotional partners and others with whom we have marketing or other relationships. At all times, in accordance with your marketing preferences, these third parties may contact you by email, SMS/text, social media or through other communications channels to tell you about products and services that they believe would be of interest to you.

At any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communicate with you.  You can ask us to stop direct marketing at any time by following the unsubscribe link you will find on all the email marketing messages we send you. Alternatively you can contact us support@numerator.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email).

You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser. We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences in your account with us. Further, if (in accordance with your marketing preferences) you receive marketing from the third parties referred to above, we recommend you review any relevant third party's privacy notice for how they use your personal information.

Be aware that if you unsubscribe from our marketing communications we may be unable to notify you of services or offer to meet your needs. If you unsubscribe from marketing communications from us, you may still receive operational and service messages from us.

ONLINE FORUMS

Please note that information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. We are unable to control any use of such information by these third parties.

FACEBOOK CONNECT

We may provide you the ability to log in to our websites using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address to pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities on our website(s) to your profile page to share with others within your network. Facebook Connect is owned and operated by Facebook, and more information about Facebook Connect is available at https://www.facebook.com 

COLLECTION OF INFORMATION FROM CHILDREN

None of our products or services are intended for use or purchase by children. Accordingly, we do not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us at privacy@numerator.com 

INFORMATION FROM THIRD PARTIES

We may receive information about you from third party companies that specialize in collecting publicly available information. This may include estimated demographic information and information from public registers, such as the electoral register. We may link information about you that we collect from these third parties with other information that we collect about you.

CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may change from time to time so please review it frequently.  We will post any Privacy Policy changes on this page and notify you if we make material changes.

ACCESS, DELETION, AND/OR CORRECTION OF YOUR PERSONAL INFORMATION

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account and contacting us through our support channels or contacting us at privacy@numerator.com.  We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, verify your identify, or may need to retain your personal information in order to continue providing a service.   

LEGAL RIGHTS AVAILABLE TO EU DATA SUBJECTS

Subject to applicable law, you have the right to request access to the personal information we maintain about you, rectification of your personal information if it is inaccurate or outdated, or erasure of your personal information in certain circumstances specified by applicable law. You may also request the restriction of the processing of your personal information or object to that processing on grounds relating to your particular situation. In addition, and subject to applicable law, you have the right to receive a copy of your personal information in a structured, commonly used, machine readable format, and, in some cases, may have the right to have that personal information transmitted to another organization.

You can exercise your rights by sending a request to privacy@numerator.com or to the mailing address referenced in the Contact Us section. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

SERVICES PLATFORM

On our service platform (e.g., Numerator Insights), Numerator collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer or employee of one of our clients and would no longer like to be contacted by one of our clients that uses our service, please contact the client that you interact with directly. 

Numerator acknowledges that you have the right to access your personal information.  Numerator has no direct relationship with the individuals whose personal data it processes on our service platform. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Numerator’s client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.  

MOBILE APPS

For privacy information related to Mobile Apps owned by Market Track, LLC, please see the  ReceiptHog Privacy Policy and/or the Shoparoo Privacy Policy 

CONTACT US

The primary point of contact for all issues arising from this Policy is our Data Protection Officer. Our Data Protection Officer can be contacted in the following ways:

Email: privacy@numerator.com

Attn: Numerator Privacy

Market Track, LLC

233 S. Wacker, Suite 2105

Chicago, IL 60606

Phone: +1.312.529.5102 

If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

To contact your data protection supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority. For the EU, your local authority can be found here.

FOR CALIFORNIA CONSUMERS

Pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), this section provides additional information to California consumers whose personal information we may collect.  This section supplements the information provided elsewhere in the Privacy Policy and applies solely to California consumers. 

Notice of Collection and Use of Personal Information

As described elsewhere in the Privacy Policy in more detail, we may collect, and may have collected during the past 12 months, the following categories of personal information about you: 

  • Identifiers: including real name, postal address, unique personal identifier (such as cookies, mobile ad identifiers and similar technology), internet protocol address, email address, account name, and other similar identifiers
  • Protected Classifications: characteristics of protected classifications under California or federal law
  • Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history and information regarding your interaction with websites, applications or advertisements 
  • Geolocation Data
  • Employment Information: professional or employment-related information 
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Additional Data Subject to Cal. Civ. Code § 1798.80: such as physical characteristics or description, education, bank account number, credit card number, debit card number, and other financial information
  • Inferences: inferences drawn from any of the information identified above

We may use, and may have used during the previous 12 months, these categories of personal information for the purposes described in our Privacy Policy (under the heading “Personal Information We May Collect And How We May Use It”), including for the business purposes that are specified in the CCPA.  

Sharing/Sale of Personal Information

As further described in our Privacy Policy under the heading “How We May Share Personal Information With Third Parties”, from time to time (including during the previous 12 months), we may share each of the above categories of personal information with third parties for the business purposes that are specified in the CCPA.  

Under the CCPA, the term “sell” is broadly defined to include several different kinds of data sharing with third parties for monetary or other valuable consideration.  Under this definition, we may sell your personal information in exchange for monetary or non-monetary consideration in the following way, as described in our Privacy Policy under the heading “How We May Share Personal Information With Third Parties”:  We may allow certain third party online advertising services to collect your personal information via automated technologies on our sites or services.  We may share the following categories of personal information for online advertising purposes:  Identifiers and/or Online Activity 

You have the right to opt out of these disclosures of your information, as detailed below.

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age. 

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.  

Deletion: You have the right to request that we delete certain personal information we have collected from you. 

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. 

How to Submit a Request. To submit an access or deletion request, or to opt-out of the sale of your personal information, please either email us at privacy@numerator.com or mail us at the address provided in our Privacy Policy under the heading “Contact Us”.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you have an account with us, we will verify your identity by requiring you to sign in to your account and/or answer security questions related to your account.  If you do not have an account with us, or an email address on file with us (such as if you signed up to receive our marketing emails), then there may not be a reasonable method by which we can verify your identity to the level of certainty required by the CCPA.  This is because historically we have not linked device identifiers or advertising IDs to named actual persons.  Accordingly, if you do not have an account with us, or an email address on file, and you request access to or deletion of your personal information, we will not be able to process your request at this time.  If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, then (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This section is available in alternative formats upon request.  To request it in an alternative format, please either email us at privacy@numerator.com or mail us at the address provided in our Privacy Policy under the heading “Contact Us”.