For more information about the Company and our services, please see our websites at www.pulpo.com.
We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising and the Code of Conduct of the Network Advertising Initiative (NAI).
TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect several types of information from and about users of our Sites, which may include information defined as personal data or personally identifiable information under an applicable law (“Personal Data”). For example, we may collect information such as your name, birth date, gender, county, zip code, e-mail address, telephone number, address, job title, company/organization name, current supplier status, social media credentials (including profiles when you subscribe to specific websites), and information related to inquiries and requests. We also may collect information about the internet connection and equipment you use to access our Sites. As you navigate through the Sites, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.
Information You Give to Us. The information we collect on or through our Sites may include:
Information you voluntarily provide when submitting an order form or other request to receive information, products, or Services on our Sites or a third party website or platform. The order form will ask you to give us contact information (like name or email address), financial information (like account or credit card numbers), and demographic information (like zip code or age).
Information you submit to us when/if you get in touch with our customer service, technical, or legal team, or any other employee at Pulpo, via contact form, email, chat or through other means.
Information you provide when you download any software or application made available to view and/or download in connection with Services that is owned or controlled by Puplo and/or its licensors, affiliates and suppliers.
Information you provide us for registering for or using any of our Services.
Information that you provide by filling in forms and applications on our Sites, including your username, password, your name, birth date, gender, county, zip code, e-mail address, telephone number, address, job title, company/organization name, current supplier status, social media credentials (including profiles when you subscribe to specific websites), and information related to inquiries and requests.
Information you provide when interacting with one of our Services, including participating or communicating in any public chat rooms, blogs, forums, message boards, news groups, or any form of communication in connection with the Sites. Please note that submitting an online comment is public and generally accessible to, and may be collected and used by, third parties. Pulpo is not liable for the distribution of your Personal Data that is put on a public forum.
Information given to us when you apply for career opportunities through the Sites. If you choose to apply online with Pulpo, Pulpo will collect any Personal Data provided in your application materials, for the purposes of reviewing and responding to your application, if appropriate.
Information you provide when signing up for newsletters and other types of informational material when you inquire about products, technical support, and customer service; and when you provide feedback about our Sites.
Records and copies of your correspondence with us (including e-mail addresses).
Information that you provide us by voluntarily conducting an online survey, contest, sweepstakes, or other online promotional activity administered by us. These activities may ask you for contact information (like name or email address) and demographic information (like zip code or age).
Information you provide us when you request information about an offer advertised through our network.
Information you provide us when you enter into a transaction through an offer delivered through our network or Sites.
Information you provide us when you request services from advertisers on whose behalf we provide fulfillment services or place online advertisements.
If you give us the Personal Data of a third party, you represent that you have provided notice to, and received authorization to provide such information from, that third party. Please note that in some cases, if you choose not to provide Personal Data you may not be able to engage in these services.
Information We Collect About You. As with many other websites, as you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type. This may include data considered to be Personal Data in some jurisdictions, such as IP address or Device ID.
Details of your visits to our Sites, including the resources that you access and use on our Sites, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.
Details of referring websites (URL).
The information we collect automatically is statistical data that helps us improve our Sites and deliver a better and more personalized service, including by enabling us to:
Determine website traffic patterns.
Count web visits.
Manage and improve the Services.
Conduct security and monitoring practices.
Determine traffic sources so we can measure and improve the performance of our Sites.
Help us to know which pages and content are the most and least popular.
Observe website search patterns to provide more intuitive navigation cues.
Determine the frequency of user visits and last date of visit.
We may share this information, and other non-Personal Data, with advertisers or other third parties that are not part of the Pulpo family on an aggregate or other basis that does not disclose your identity or contact information. We may also obtain Personal Data and make it Non-Personal Data by, for example, removing personally identifiable elements (such as your name) or by aggregating Personal Data with information about other individuals in order to “anonymize” or “de-identify” the information. We may also augment the Personal Data and Non-Personal Data we collect with information from other sources, including, for example, zip code, age, gender, language preference or income range in order to generate aggregate information that reflects activities, habits, preferences, or interests about our users as a group. We do not knowingly collect, use or share any financial account numbers or social security numbers for purposes of online behavior advertising without your specific consent.
HOW WE USE YOUR INFORMATION
Below please find information about how we process information collected about you (including Personal Data). We may process information about you, including Personal Data, where the processing is:
Necessary to personalize your experience. We may use the Personal Data you give us to better tailor your Sites experience to your interests, and to send you information about Pulpo and its Services as well as promotional material on behalf of some of our partners. We use other information, including Personal Data, that you provide to us to show you content in which you may be interested and to display the content according to your preferences. We will also share this information within the Pulpo family in order to enhance your experience on the Sites and other Pulpo websites.
Necessary to advertise and market products and services of third-parties outside Pulpo with whom we do business (“Business Partners”), including to present content that is tailored to your interests, including online behavioral advertising and to analyze the effectiveness of advertising, promotions, and offers.
Necessary to conduct research and analysis, product development and reporting, including to better understand our audience; produce data analytics, statistical research, and reports; and to review and change our products and services.
Required by law.
Necessary to provide access to certain features on the Sites and receive information suited to their interests.
Necessary to contact you with information about the Pulpo family and promotional material on behalf of some of our partners, and to contact you when necessary.
Necessary to administer our Sites, help diagnose problems with our servers, to analyze trends, to track users’ webpage movements, to help identify you and your shopping cart, and to gather broad demographic information for aggregate use.
Necessary for us to comply with a legal obligation.
Necessary for entering into or the performance of a contract with you. For example:
To carry out our obligations arising from any contracts entered into between you and us.
To provide you with the information, products, and Services that you request from us.
To process your supplier application and registration form, and to create online accounts for your organization and its authorized agents.
To communicate with you about our contracts or your account.
Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
To make sure that content from our Sites is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of our Sites and Services (when you so choose).
To keep our Sites safe and secure (for example, security protection and fraud prevention).
To provide you with technical support and to improve our Sites and Services.
To provide you with information that you have requested and respond to your inquiries.
To notify you about changes to our Services or our Sites.
To manage our everyday business needs, such as auditing, administration of our Services, analytics, and the enforcement of any corporate reporting obligations, or other policies.
Necessary to investigate and enforce, if necessary, a user’s legal requests, including, but not limited to, potential copyright or intellectual property infringements.
Pursuant to valid consent provided by you, in order to provide you with information about goods or Services we feel may interest you. If you do not want us to use your Personal Data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data.
Allowed for any other purpose where you have provided valid consent where it is legally required.
disclosure of your information
When you apply on the Sites for a job, we may, in our sole discretion, forward the information you submit to our parent, subsidiaries and affiliates for legitimate business purposes.
To companies that are affiliated with Pulpo, that is, are controlled by, or under common control with, Pulpo.
To companies that are affiliated with us, that is, are part of Pulpo.
To our Business Partners so that they may market and advertise their products and services, administrate and manage transactions and relationships with audiences, and personalize user experiences for audiences.
To advertisers and business partners that are not affiliated with Pulpo, but would like to send you information about their products and services. For example, some of the companies who supply prizes for Pulpo’s contests may have special offers or promotions that might be of interest to users of the Pulpo Sites. We will not share your Personal Data with such third parties without your permission.
To perform tasks (such as order fulfillment and payment processing) required to complete purchases you make through Pulpo. Pulpo must disclose your credit card information with such third-parties to complete any payment transaction on our Sites.
To third parties who assist us in operating our Sites, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.
With outside contractors, vendors, or agents who help us manage our information activities (i.e., message boards, sweepstake administration, order fulfillment, sweepstakes and prizes, storage, market research, reporting, hosting, technical support, statistical analyses, data processing, and other purposes), or with outside contractors, agents, vendors, or sponsors who help us with administration, judging and prize fulfillment aspects of contest, promotions, and sweepstakes. These outside contractors, agents, vendors, or sponsors may only use your Personal Data to provide Pulpo with a specific service and not for any other purpose without your consent. Pulpo may only provide your Personal Data to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your Personal Data.
With third parties where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your Personal Data.
With third parties who help us customize our advertising and marketing messages you receive on our Sites, or may work with outside companies to do so. Your non-Personal Data may be shared with these companies so this customization can be accomplished. Pulpo prohibits these companies from sharing your information with any third party or from using it for any purpose other than targeting advertising.
To protect the safety or security of individuals, such as to: (1) comply with the law or legal process or cooperate with law enforcement; (2) protect the safety and security of users or members of the public; (3) protect or defend the legal rights of the Company, its employees, agents, advertisers, publishers or other contractors (including enforcement of agreements); (4) protect against fraud or for risk management purposes; (5) protect or enforce our Sites policies; or (6) protect the rights, property or safety of the Company or the public. Except where required by law, we may share non- Personal Data in other ways without restriction.
With third-parties regarding specific registration modules, like survey, contests or sweepstakes. We will post a conspicuous statement on the registration module to the effect that we will be sharing with third parties the Personal Data and information collected.
When necessary to support certain functions and features of our Sites. For example, this may occur at a feature that enables you, via our Sites, to ask questions of persons or entities that are not part of the Pulpo family. By responding to those features of the Sites, whether by email or direct entry of information on our Sites, you are consenting to our transferring that information to such persons or entities.
To comply with the law or a legal process, such as a court order or any regulatory proceeding.
JURISDICTION AND CROSS-BOARDER TRANSFERS OF PERSONAL DATA
The Sites and Services are intended for use in North America and Latin America. The data that we collect from you will be transferred to, and stored and processed in, the United States. Please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country.
Pulpo employs commercially reasonable security measures consistent with standard industry practice for information collected through the Sites. We believe that we have adequate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of the information we collect on our Sites. We also use internal protections to limit access to users’ Personal Data to only those employees who need the information to perform a specific job. You should be aware that the Internet is inherently susceptible to security failures beyond Pulpo’s control, and you should keep this in mind when communicating any information.
THIRD PARTY LINKS
This Pulpo Sites may contain links to websites operated by third parties. Pulpo does not monitor or control these sites and makes no representations regarding these links. Pulpo is not liable or responsible for the accuracy, completeness, timeliness, reliability or availability of any of the content uploaded, displayed, or distributed, or products or services available at these sites. If you choose to access any third-party site, you do so at your own risk. The presence of a link to a third-party site does not constitute or imply Pulpo’s endorsement, sponsorship, or recommendation of the third party or of the content, products, or services contained on, or available through, that site.
To save and remember registration information or preferences that you may have set while browsing the Sites.
To deliver content specific to your interests.
To save your password so you don’t have to re-enter it each time you visit our Sites.
We may also use “session cookies” which helps us administer the Sites. The session cookie expires when you close your browser and does not retain any information about you after it expires.
You can program your computer to warn you each time a cookie is being sent, block third party cookies or block all cookies. However, by blocking all cookies you may not have access to certain features on the Services.
Some of the advertisements that appear on Pulpo are delivered to you by third party Internet advertising companies. These companies utilize certain technologies to deliver advertisements and marketing messages and to collect anonymous information about your visit to or use of our Services, including information about the ads they display, via a cookie placed on your computer that reads your IP address. To opt out of information collection by these companies, or to obtain information about the technologies they use or their own privacy policies, see their individual websites.
By using the Sites, you expressly consent to the use of Google Analytics on your activities on the Sites. You also can opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: (click here).
OPTING OUT OF INFORMATION COLLECTION
You can opt-out of having the Company collect or use information about you for online behavior advertising by clicking here or going to the website www.tentaculos.net/opt-out/ and following the instructions, and we will place an opt-out cookie on your computer. You may also use the NAI opt out tool by clicking here or going to the website www.networkadvertising.org/choices. The opt-out process is computer, device and browser specific and therefore must be repeated on each computer, device and browser that you use (for example, from within INTERNET EXPLORER AND FIREFOX). Please note that deleting, blocking or otherwise restricting cookies on your computer or device may delete our opt-out cookie and require you to renew your opt-out choice.
Many browsers can be modified to prevent automatic acceptance and notify you every time a cookie is sent to you or to allow you to choose not to receive cookies at all. If you wish to change the settings on your browser to block cookies, please follow the instructions applicable to the web browser that you are using.
We may license ad-server software from another company to place banner advertising on our Sites. All of the data provided and generated by the ad-server software remains in our possession and no data is transferred to the licensor of the software. This feature of our Sites may, on occasion, set “cookies” on your computer. Any information collected or stored by the ad-service or the cookies is treated in the same manner as other information as described in this statement.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Pulpo strives to provide you with choices regarding the Personal Data you provide us. We have created mechanisms to provide you with the following control over your information:
Cookie Settings: If you do not wish for us to install cookies on your device for the purposes described above, you may change the settings on your browser to block or limit cookies. For more information, please see http://www.aboutads.info/consumers. Please note that if you block or limit cookies, you may not be able to use all of the features of the Sites.
Do Not Track Signals: We do not currently respond to “do not track” signals.
Opt Out of Receiving Email Message: This Pulpo Sites provides you the opportunity to opt-out of receiving email communications from us and our special relationship partners. To opt-out of receiving email communications, you:
May use the unsubscribe link provided in promotional communications;
May modify your registered user information on our Sites; or
May send an email to firstname.lastname@example.org.
Opt Out of Receiving Promotional Materials: If you receive promotional materials from Pulpo, and want to stop receiving such materials, click the unsubscribe link at the bottom of each promotional email.
CHILDREN UNDER THE AGE OF 16
Our Sites is not intended for children under 16 years of age, and Pulpo does not knowingly collect or use any Personal Data from children under the age of 16. No one under the age of 16 may provide any information to or on the Sites. If we learn we have collected or received Personal Data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at email@example.com.
CALIFORNIA PRIVACY RIGHTS
Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of Personal Data we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to:
c/o Legal Department
Entravision Communications Corporation
2425 Olympic Boulevard
Suite 6000 West
Santa Monica, CA 90404
SECURITY AND RETENTION
We employ reasonable measures to protect the security of information that we collect. Unfortunately, no transmission of information and no data storage can be guaranteed to be completely secure and unauthorized access to data, hardware or software failure, and other factors may compromise data security. As a result, while we strive to protect your Personal Data, we cannot guarantee or warrant the security of any such information, and you provide any information, including Personal Data, at your own risk.
We retain Personal Data for a maximum of six months from the last time a user is tracked to fulfill the delivery of advertising; administer transactions; conduct research and analysis, product development and reporting; comply with the law or legal process; protect or defend the legal rights of the Company, its employees, agents, advertisers, publishers or other contractors (including enforcement of agreements); protect against fraud or for risk management purposes; protect the rights, property or safety of the Company or the public; or as required or permitted by law or with your consent. We may retain Non- Personal Data indefinitely.
We retain user-level data for Personalized Advertising or Ad Delivery and Reporting for a maximum duration of 90 days.
PUBLISHER SOURCING DISCLOSURE
Paid traffic sources percentage in Entravision/Pulpo Properties: Q1 2017 less than 1% of total visitors; Q2 2017 less than 1% of total visitors; Q3 2017 less than 1% of total visitors. A visit is considered “acquired through paid sources” if the first page view is from a paid source. A visit is determined to be from a paid source based only on attributes collected during that visit.
February 25 2019