TRIAD DIGITAL MEDIA, LLC d/b/a TRIAD RETAIL MEDIA PRIVACY POLICY

1. Introduction

Triad Digital Media, LLC d/b/a Triad Retail Media (“Triad”) creates, manages and operates online media programs for leading retail e-commerce websites, delivering innovative, custom digital ad campaign opportunities to national brands to reach, target and engage shoppers at exactly the right time and place — while they’re researching brands and making final purchase decisions.

Triad may occasionally change the features and content found on this site. Triad reserves the right, at its discretion to change, modify, add or remove portions of this privacy policy. Consequently, our privacy policy may be modified to reflect any revisions to the site. We suggest you revisit our privacy policy from time to time to be sure that you are familiar with our practices.

2. Information Collected

  1. Personally Identifiable Information
    In some instances, this website (the “Site”) may collect personally identifiable information (name, address, e-mail address, telephone number, fax number, credit card information and information about your interest in and use of various products, programs and services, etc.) This information is only collected when volunteered by the user.

  2. Non-personally Identifiable Information
    This Site also collects non-personally identifiable user information, such as Internet Protocol (IP) addresses, “cookies,” “pixel tracking,” and Internet tags and navigational data (server log files). This information is used for system management and to improve the content and navigation of the site.

    We do not match personally identifiable information with non-personally identifiable information. In other words, we do not link personal information (name, etc.) with visit information, such as pages visited or files downloaded. In effect, all such visit information is anonymous.

    "Cookies" are small pieces of information that are stored by your web browser software on your computer's hard drive or temporarily in your computer's memory. The use of cookies is now an industry standard, and users will find them on most major web sites, Triad may place and store Internet cookies on a user's hard drive. Cookies can save any of the types of information noted above. Cookies enable us to recognize you and personalize your viewing experience on the Triad site. We also use cookies to store user names and information that are supplied at registration. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on the site will not function properly if your web browser does not accept cookies.

    "Pixel tracking", a common process which may be used in connection with advertisements on other sites, involves the use of pixel tags that are not visible to the user of the site and consist of a few lines of computer coding. Pixel tracking measures the effectiveness of these advertisements and compiles aggregate and specific usage statistics. A "pixel tag" is an invisible tag placed on certain pages of websites you may visit and is used to track an individual user's activity. We may access these pixel tags to identify activity and interests that may allow us to better match our offers with your interests. For example, if you visit our Site from an advertisement on another site, the pixel tag will allow the advertiser to track that their advertisement brought you to the Triad web site. If you visit our website and we link you to another site we may also be able to determine that you were sent to and/or transacted with a third party web site. This data is collected for use in our marketing and research. Personally identifiable information about you is not collected by the third party advertising company, nor is any tracking information generated from the pixel tag allowed to be used by them for any other purpose other than to report web site activity to us.

3. Use of Information

We will use the information you submit to improve the Triad web site and to improve the information about Triad and its clients that may be of interest to you. You will only receive an e-mail from us for information you have requested or as confirmation of information that you submitted (i.e. contact form). You may opt-out of receiving information from Triad at any time by following the unsubscribe information provided in the e-mail or in writing by contacting:

Privacy Policy c/o Triad Digital Media, LLC d/b/a Triad Retail Media
100 Carillon Pkwy., Ste. 100
Saint Petersburg, FL  33716
Email to: privacy@triadretail.com.

4. Information Disclosure Policy

Any personally identifiable information you submit to us is for exclusive use by Triad or other entities that are involved in the operation or fulfillment purposes of this site. We do not sell, license, trade or rent personal information about our users. In the event of a merger, acquisition, or change of control of Triad, customer data would be considered a business asset and would be transferred. We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We may also disclose personal information as required by law or to protect the safety and security of our users.

5. Links to Other Web Sites

This site contains links to other Web sites. Please be aware that this Privacy Policy does not apply to any other Web site. For your own protection, read the privacy policy of each Web site that you visit since these sites may independently collect or request information about you.

6. Links to Other Web Sites

We have implemented a number of security features throughout the Triad site that are intended to prevent the unauthorized release of or access to the user information we collect online. For example, database information is firewall protected, password protected and our web security is reviewed on a regular basis. Access to personal information is limited to key management personnel and our IT department. While we strive to create a secure and reliable site for our users, the confidentiality of any communication or material transmitted over the Internet cannot be 100% guaranteed. Users should keep in mind that any information submitted through an Internet transaction is potentially accessible to the public, and consequently, can be collected and used by others without their consent. Triad is not responsible or liable for illegal interception of personal data via any Internet transaction.

7. Sweepstakes, Instant Win Games and Contests

Periodically, sweepstakes, instant win games and contests may run on our site. Sometimes, sweepstakes, instant win games and contests are sponsored by our customers/clients. To enter these sweepstakes, instant win games and contests you need only to enter your email address and password. Winner’s names are NEVER shared with our customers without their consent.

Triad may sometimes also offer our members the opportunity to participate in sweepstakes, instant win games and contests from third parties. In these cases you will be linked to the third party web site and you may be asked for personal information, such as name, address, gender, etc. This information is collected by the third party, and will be used in accordance with their privacy policy. Please read the privacy information posted on that third party web site to make sure you are comfortable with it before entering your information.

8. Adherence to Principles

If at any time you believe this site has not adhered to these principles, please notify us by email privacy@ triadretail.com and we will use all commercially reasonable efforts to promptly determine and correct the problem.

9. Your Consent

By using our Web site you consent to the collection and use of the information you provide to us as described above. If we are going to use your personally identifiable information in a manner different from that stated at the time of collection, we will notify you via e-mail. You will have a choice as to whether or not we use your information in this different manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our web site notifying users of the change. In some cases where we post the notice we will also e-mail users, notifying them of the changes in our privacy practices. By using this site, you signify your acceptance of the Privacy Policy. If you do not agree to this policy, please do not use our Web site.

10. Children’s Privacy

Unless otherwise specifically indicated, Triad promotions are not available to anyone under the age of thirteen (13). Triad may, however, operation some promotions on behalf of its clients which collect personally identifiable information from children under the age of 13. In each such instance, Triad and its clients will comply fully with all aspects of the Children’s Online Privacy Protection Act (“COPPA”) in the operation of the Promotion, collection of the information and in the subsequent use of the data collected. Personally identifiable information will not be collected from children under the age of 13 without parental consent in compliance with the COPPA g11.

11. California Privacy Rights

As provided by California Civil Code Section 1798.83, a California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the publish 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, as long as the business maintains and discloses this policy. Rather the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

12. Safe Harbor Compliance: Privacy Principles Concerning Information Collected/Transmitted from the European Union

The following privacy principles specifically pertain to information collected/transmitted from the European Union (“EU”). Triad complies with the US-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Triad has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/

NOTICE: When Triad collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Triad discloses that information, and the choices and means, if any, that Triad offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Triad, or as soon as practicable thereafter, and in any event before Triad uses the information for a purpose other than that for which it was originally collected.

If Triad receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.

CHOICE: Triad will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Triad will provide individuals with reasonable methods to exercise their choices.

DATA INTEGRITY: Triad will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Triad will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Triad will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Triad has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Triad will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Triad will grant individuals reasonable access to personal information that it holds about them, and Triad will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Triad will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Triad will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Triad determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

QUESTIONS/CONCERNS AND DISPUTE RESOLUTION: Triad commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact Triad at:

Privacy Policy c/o Triad Digital Media, LLC d/b/a Triad Retail Media
100 Carillon Pkwy., Ste. 100
Saint Petersburg, FL  33716
Email to: privacy@triadretail.com.

For concerns or complaints that cannot be resolved between Triad and the complainant, you may contact the American Arbitration Association ("AAA") (International Centre for Dispute Resolution (“ICDR”)) as an independent dispute resolution mechanism. For Personal Data collected in support of Human Resources Operations, Triad has agreed to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.

13. Further Questions

We welcome any questions or comments you may have regarding this privacy policy or the use of personal data. In addition, if you wish to contact correct, amend or delete information about privacy related issue or for any reason at all, you may do so in mailing your request to: Privacy Policy c/o Triad Digital Media, LLC db/a Triad Retail Media, 100 Carillon Pkwy., Ste. 100, Saint Petersburg, FL  33716
or email to: privacy@triadretail.com.

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