PRIVACY POLICY

Last Updated and Effective: 11/15/2023

This Privacy Policy applies to the CinqDI platform, including all of its features and functionality thereof (the “Services”), owned and operated by MV Digital Group, LLC (“MVD,” “we,” “us”). This policy explains how we may collect, use, and disclose personal information of visitors to or users of the Services (“you” or “your”). Personal information is data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). This policy also explains your choices regarding use, access, and changes to your Personal Information.

Visitors to and users of our Services are typically employees of an organization or entity that has purchased the Services (a “Customer”). For the sake of clarity, our collection and handling of your Personal Information is also governed by our agreement with the Customer.

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services.

Please also review the Terms of Use, as that is an agreement between you and us that governs your use of the Services. Your use of certain features and functionality of the Services may also be governed by the Customer’s agreement with us.

 Contents

• Information We Collect
  • Usage Information
  • Third Party Cookies and Tracking
• How We Use and Disclose Your Personal Information
• How You May Modify Your Information
• Third Parties
• Links
• Security
• Data Retention
• Opt-Out Policy
• Notices For California and Other US Residents
• Updates to This Policy
• Contact

 Information We Collect

When you access or use our Services, when you request customer support or information about our Services, or when you otherwise communicate with us, we may collect certain Personal Information about you. This Personal Information includes your first and last name, email address and password, organization name and industry/type, individual role and seniority, and advertising categories of interest, which we use to create, maintain, and support your account in the Services. In addition, we will ask you to provide the Customer social media or other ad platform account IDs if you choose to activate those accounts within the Services.

If you choose to purchase a subscription within the Services, we will also request payment information, including your first and last name, organization name, email address, phone number, billing address, and payment method. Credit card number or other payment method details will be collected and processed by our third-party, PCI-compliant payment processor.

Usage Information

In addition, when you access our Services, our servers automatically collect the Internet Protocol (“IP”) address associated with your computer. We may also collect additional information such as a browser type and version, the operating system of your device and language, country, as well as areas in the Services you visit most frequently and when. If you log into any features or functionality of the Services, we also collect the login timestamp. We use this information to help us administer the Services, remember your preferences, and diagnose technical problems.  We also analyze the information for aggregate trends about how our Services are used and to help improve the Services.

To collect this information, we may use the following technologies:

Cookies. Cookies are small data files sent by a Services and stored on the computer or device at the request of that site. Cookies store information related to a user’s browser to enable us to recognize the browser on return visits to our Services and to remember your preferences.

Pixel tags. A pixel tag (also referred to as a “clear gif” or “web beacon”) allows us to track the online usage patterns of the Services and to understand which links are clicked, or when you open emails that we may send to you. We use this information to help us improve the Services and our communications.

HTML5 Storage. HTML5 storage or local storage allows us to distinguish your device from others and to remember information that might be important for the functioning of the Services, such as to remember your logged in state. Typically, HTML5 storage is only deleted if all Internet history, cache, and cookies are deleted. Check your browser controls for information on how to delete your HTML5 storage.

Third Party Cookies and Tracking:

We use third-party service providers, including Google Analytics, to assist us in collecting and understanding usage information. To learn more about Google Analytics, visit their privacy policy. You may opt out of Google Analytics by downloading their browser add-on, available at https://tools.google.com/dlpage/gaoptout. Note that we are not responsible for their opt-out tool.

Most browsers can be set to detect browser cookies and to let a user reject them, but refusing cookies may affect certain Services features that are provided for your convenience. To learn more about browser cookies, including how to manage or delete them, refer to the “Tools,” “Help,” or similar section of your web browser.

How We Use and Disclose Your Personal Information:

We use and disclose your Personal Information for the purposes described above and for the following:

• To administer our Services, including to create and manage log-in credentials, provide security, maintenance, and support;
• To investigate a suspected violation of our Terms of Use, suspected fraud or other unlawful activity;
• To respond to your inquiries and to solicit your feedback;
• In connection with legal or regulatory obligations and to protect our rights or the rights and safety of others, including as may be required by law or by a court order;
• To our third party service providers to allow them to provide features and functionality for the Services on our behalf;
• In the event of a reorganization, merger, sale, bankruptcy or other business change; and
• With your consent and as permissible under applicable laws and regulations.

 

How You May Modify Your Information 

If you would like to review, correct, update or request that we delete Personal Information you have provided to us, or to exercise other lawful rights related to your Personal Information please contact us at and specify what you would like to review, correct, update or have deleted.

 Third Parties

We may engage with third parties to facilitate our delivery of our Services and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, email and marketing management, payment processing, security and similar functions. These third parties may require a limited amount of information, including Personal Information, in order to deliver their services.

We may also retain, use and share aggregated demographic information that is not linked or linkable to Personal Information for legally permissible purposes.

Links

Our Services may contain links to third party websites and platforms, including social networking websites and advertising account platforms (“Linked Sites”).  The fact that we provide a connection to a Linked Site is not an endorsement or representation of an affiliation with that Linked Site. We do not control Linked Sites or their privacy practices. The companies that operate Linked Sites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the Linked Sites you connect to within the Services or otherwise visit.

Security

We implement physical, administrative, and technical safeguards to help protect the confidentiality, integrity and availability of your Personal Information.  The Internet, however, is not perfectly secure, and no system of physical or electronic security is impenetrable, so we cannot guarantee the security of your Personal Information or the security of servers, networks or databases. We are not responsible for security breaches not reasonably within our control.

You are responsible for maintaining the confidentiality of your account credentials. If you become aware of any unauthorized use of your account credentials or suspect a security compromise, please promptly notify us at admin@cinqdi.com.

Data Retention

We retain Personal Information for as long as is necessary to provide you with access to our Services or as long as is permissible under applicable law, including as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, comply with applicable industry standards, and protect the security of our Services. How long we retain specific Personal Information varies depending on its type and use, as well as our contractual obligations with the Customer.

Opt-Out Policy

We may send you emails with information about our products and services that we believe may be of interest. You may opt out of receiving these email messages from us by clicking on the “unsubscribe” link found at the bottom of every email that we send or by contacting us at admin@cinqdi.com.

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Notice For California and Other US Residents

Certain US state laws, including California, provide their residents with certain rights related to their Personal Information, as described below. We provide these rights to all US residents.  Before we may fulfill a request in relation to our Services, we may be required by law to verify your identity in order to prevent unauthorized access to your data.

We do not engage in behavior that California and other state laws refer to as a “sale” or “sharing” of your Personal Information.

Users wishing to exercise the rights described in this section should contact their employer. We will work with the Customer as needed should they require our assistance in fulfilling the requests. If you are the Customer, please contact us at admin@cinqdi.com and specify the right(s) you wish to exercise.

Please note that your exercise of the above rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We will try to comply with your request as soon as reasonably practicable in compliance with time frames set forth under applicable law. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of any reasons why we are unable to honor your request.

Right to Know and Access Information: You have the right to request access to the Personal Information we maintain about you in the ordinary course of business and to receive it in a machine-readable format so that it is available to you. This may include Personal Information we collect, use, or disclose about you.

Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you.

 Right to Delete: You have the right to request that we delete your Personal Information. In the case of all such requests, we may not fulfill all or part of the request as permitted or required by applicable law. For example, if you request that we delete your Personal Information, there may be certain records we are legally required to retain.

 Non-discrimination: We will not discriminate or otherwise penalize anyone for exercising their rights under applicable law or this Privacy Policy.

The following reflects our current practices and our practices that have been in place over the past 12 months.

Categories of Personal Information we collect	●      First name, last name, email address, and password; ●      Online identifier, Internet Protocol address; ●      Internet or other electronic network activity information related to your use of our Services; ●      Categories of advertising or audience segments of interest; ●      Organization name, industry, and individual role and seniority level; ●      Account IDs for Customer account activation; ●      Billing contact, including first and last name, organization name, email address, phone number, billing address, and payment method for those who choose to purchase a subscription via the Services.
Categories of sources from which the Personal Information is collected	We collect the Personal Information directly from you, from the Customer, or automatically through the Service as described above.
Business or commercial purpose for sharing or selling Personal Information	We collect your Personal Information to operate the Services, respond to your requests and for the following business purposes: ●      Providing the Services in accordance with our contract with the Customer and our Terms of Use, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments; ●      Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; ●      Debugging to identify and repair errors that impair existing intended functionality; ●      Sending you information and updates about our Services. ●      Improving the Services.
Categories of third parties with whom we share Personal Information	We do not share your Personal Information with individuals or organizations to use for their own or others commercial purposes. We disclose your Personal Information only to service providers who support us in delivering the services as described above.
Specific pieces of Personal Information we have collected	●      First name, last name, email address, password; ●      Internet Protocol address, device ID; ●      Internet or other electronic network activity information, including, but not limited to, how you use the Services; ●      Categories of advertising or audience segments of interest; ●      Organization name, industry, and individual role and seniority level; ●      Account IDs for Customer account activation; ●      Billing contact, including first and last name, organization name, email address, phone number, and billing address, and payment method for those who choose to purchase a subscription via the Services.

 

California “Shine the Light” Rights:
If you are a resident of California, you may request certain information regarding our disclosure of Personal Information (if any) for marketing purposes.  To make such a request, please contact us at: MV Digital Group, One World Trade Center, New York, New York 10007.

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Updates to This Policy:

As our Services evolves, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within the Services or otherwise as required by law. The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted.

Contact:

If you have any concerns or complaints about how we handle your Personal Information, or if you have questions regarding this Privacy Policy, please contact us at MV Digital Group, One World Trade Center, New York, New York 10007 or at admin@cinqdi.com.