Dialogfeed complies with the U.S.-EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information (defined below) from European Union member countries. Dialogfeed 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.
Privacy Practices by User Category:
- Privacy Practices for Visitors to the Dialogfeed Site
- Privacy Practices for End Users Who Use the Dialogfeed Sharing Platform on Publisher Sites
- Privacy Practices for End Users Who Download and Use Dialogfeed Toolbars
Privacy Practices for Visitors to the Dialogfeed Site
(a) The Information We Gather and How We Use it: The Site is primarily directed to Publishers, although we welcome End Users who want to know more about our Services. When you access the Site or Services, we may collect the following information:
- Personal Information – We collect Personal Information when you knowingly provide it, including when you register for the Site, provide feedback, or request information. Personal Information is information that may be used to identify or locate an individual, like a person’s full name, postal address, e-mail address, or phone number, as well as other non-public information that is associated with this Personal Information. We use your Personal Information to administer your account and provide you services, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages to those who ask for such messages. Typically, Publishers, rather than End Users visit the Site in order to access and register for the Services.
- Non-Personally Identifiable Information – We collect Non-Personally Identifiable Information automatically when you visit our Site. Non-Personally Identifiable Information is information that is not used nor intended to be used to personally identify an individual and is not associated with nor linked to Personal Information. This Non-Personally Identifiable Information we collect via the Site includes your Internet Protocol address, browser type, browser language, the date and time of your request, and the web page you have visited immediately prior to visiting the Site.
(b) Information Sharing: We share Personal Information and Non-Personally Identifiable Information collected via the Site with other companies or individuals as follows:
- When they help us operate our business, such as with vendors that assist us in sending email, marketing and customer service.
- With third parties if we have a good faith belief that access, use, or disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Dialogfeed, its users or the public as required or permitted by law.
- With any of our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred.
- With third parties to whom you ask us to send Personal Information;
- In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally-Identifiable Information of others and share that aggregated information with third parties without restriction.
(c) Forums: We make interactive forums available on the Site. Any information that you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to any interactive forum and is no longer private. Please be thoughtful about what you post and make publicly available through our interactive forums.
Privacy Practices for End Users who use the Dialogfeed Sharing Widget on Publisher Websites
As part of the Service, we operate the Dialogfeed platform, which makes social activity & engagement easy for Website. If you are reading this policy, you are probably familiar with our widgets and menus that Publishers enable on their websites to allow you to share their content through email, social networking websites, blogs and more. When you, an End User use one of our widgets, menus and/or toolboxes that is enabled on one of our Publisher websites (an “Dialogfeed Widget”), we collect certain non-personally identifiable information automatically for use on our platform (the “Dialogfeed Platform”). We enable our Publishers to use this information via the Platform for analytics purposes
(a) The Information We Gather and How We Use It:
- Personal Information – We only collect Personal Information via a Dialogfeed Widget when an End User provides it to us, and never use that information on the Dialogfeed Platform for delivering targeted advertising. When you, an End User, send an email using a Dialogfeed Widget we use your email address, the email address of the person (or people) to whom you are sending the content and allow you the opportunity to write an accompanying message. We use this Personal Information only to send the email on your behalf and for no other purpose, and it is not merged or otherwise combined with any of the Non-Personally Identifiable Information that we collect. This Personal Information will be available to the people to whom you send or share content via the Dialogfeed Widget, so please be careful.
- Non-Personally Identifiable Information – We collect Non-Personally Identifiable Information via the Dialogfeed Widget for use on the Dialogfeed Platform. For example, when you visit a web page that contains one of our Dialogfeed Widgets, our server logs collect your Internet Protocol address, browser type, browser language, the date and time you visited that web page, and (if you came to a web page where an Dialogfeed Widget is enabled via a search engine such as Google), the web search that landed you on that web page. We also collect information regarding how often you share content with others using the Dialogfeed platform. We use this information to help us build commercially viable data segments (e.g., travel enthusiast, sports fan) for online ad targeting in order to help make the ads you see on many of the websites you visit more relevant to your interests, and for ad delivery and reporting purposes. For information regarding how we use this information to help deliver more relevant advertising please see the section below entitled “Targeted Advertising and Choices.” We also set Cookies and web beacons on web pages where our Dialogfeed Widgets are enabled, and allow our partners to set Cookies and web beacons that are subject to those partners’ privacy statements. We also use this information to customize the Dialogfeed Widget to your usage patterns. For example, if you share to Facebook, we make sure that Facebook icon is at the top of your Dialogfeed Widget menu.
(b) Information Sharing.
We generally don’t share Personal Information collected via the Dialogfeed Widget except as specifically directed by the End User in order to share a piece of content via email or via social networking platform. We share information collected via the Dialogfeed Widget with other companies or individuals as follows:
- We share Non-Personally Identifiable Information with partners and the website Publishers who have the Dialogfeed Widget enabled on their websites for their own website analytics purposes. For example, we provide our publishers with statistics on sharing trends, and the top content segments shared (e.g., A blog post analyzing a speech given by the President), so that Publishers can understand how End Users are sharing their content, as well as how much web traffic such sharing brings back to the Publisher’s site. Publishers may use this information to tailor content and advertising on individual publisher sites. Publishers can use filters to refine the data by domain, time period, geography, and other options.
- We share any information with third parties if we have a good faith belief that disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Dialogfeed, its End Users or the public as required or permitted by law.
- We share information with our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred.
- In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally Identifiable Information of others and share that aggregated information with third parties without restriction.
Information Security, Retention, and Data Integrity
We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems.
We restrict access to Personal Information to Dialogfeed employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.
We retain Non-Personally Identifiable Information on the Platform for up to five years. Any search strings we collect via the Dialogfeed Widget are converted into Non-Personally Identifiable Information, and the raw search data is stored on our server logs for up to 90 days. Aggregate reports generated from such information may be kept longer.
Dialogfeed processes information in a way that is compatible with and relevant for the purpose for which it was collected.
Dialogfeed will allow an individual access to their Personal Information to the extent it is available and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. If you have provided Personal Information when registering for our Site, you may access and modify that information at any time by visiting your account settings (http://Dialogfeed.com/settings). If you’d like us to update, correct, delete, or deactivate any other Personal Information that you have provided to us, please send your request to us at info@Dialogfeed.com and we will process your request within a reasonable period of time after receipt.
We do not knowingly collect or maintain Personal Information from individuals who are under 13 years of age, and no part of our Site or Services are designed to attract people under the age of 13. Protecting the privacy of children is very important to us. If we obtain knowledge that a user is under the age of 13, we will take steps to remove that user’s Personal Information from our databases.
Links to Other Sites
The Site and Services are hosted in the United States. If you access the Site or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Site or Services, you are transferring your Personal Information to the United States and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries (including the United States) where laws regarding processing Personal Information may be less stringent than in your country.
Enforcement, Questions, and Complaints
4 Rue des Pères Blancs
Dialogfeed has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if the Privacy Officer at Dialogfeed does not satisfactorily address your complaint, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.