Hotspex Media is committed to protecting the personal information of our clients and prospective clients, as well as other users of our websites and services. It is important to us that you understand how we treat your personal information and we encourage you to read this Policy carefully.
When Hotspex Media collects and processes personal information in order to provide our services to clients, we will only process such personal information on behalf of the particular client in order to provide our services to that client. Our collection, use, disclosure and other processing of personal information on behalf of clients is subject to the privacy policy of our respective clients.
Overview
This table provides a summary of the personal information and how we use it, which is further explained in our Privacy Policy below. While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions, the table below provides a general overview of the categories of personal information we collect and the purposes for which we use such information.
Categories of personal information we collect:
Use of personal information:
Individual Rights
Please see the Your Choices and Rights section below for a description of the choices we provide and the rights you have regarding your personal information. If you are a California resident, please be sure to review the section Additional Information for Individuals in Certain Jurisdictions below for important information about the categories of personal information we collect and disclose and your rights under California privacy laws.
Hotspex Media is committed to protecting the personal information of our clients and prospective clients, as well as other users of our websites and services. It is important to us that you understand how we treat your personal information and we encourage you to read this Policy carefully.
Scope
This Privacy Policy ("Policy") explains how we process information that we collect from users of our website www.hotspexmedia.com, www.reticleai.com, and on any other websites, mobile applications or other online services that display or like to this Policy (together, the "Site"), as well as from our former, current and prospective clients and other individuals that use our products and services or communicate with us. Please note, that this Policy only applies to us but not to any third-party websites that may process, share, or distribute your personal information or other information.
Our collection, use and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information.
Personal Information. In this Policy, our use of the term "personal information" includes other similar terms under applicable privacy laws—such as "personal information" and "personally identifiable information." In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual.
Not Covered by this Policy. This privacy notice does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices.
Client Data. Hotspex Media Inc. provides programmatic support, consulting and campaign management services, facilitates and manages access to third-party services, and provides an innovative platform to clients to bring it all together (our "Services"). We may receive, access or otherwise process personal information in order to provide our Services (the "Client Data") to clients. In such cases, Hotspex Media Inc. will only process Client Data on behalf of and under the instructions of our clients and as set out in our client agreements, or where otherwise required by applicable laws.
Controller and Responsible Party
For the purposes of GDPR, Hotspex Media Inc. is the controller of your personal information. In addition, where you have a direct business relationship with another Hotspex group entity, they are a controller for the personal information they used to manage their direct business relationship with you, such as name and contact details. With respect to any Client Data, our clients are the data controllers or businesses for their respective Client Data, and we are a data processor or service provider with respect to Client Data.
Information We Collect
The personal information that we collect and process will vary depending upon the circumstances. You do not have to provide us with your personal information to access much of our Site. However, if you choose not to disclose certain information, we may not be able to provide certain Services to you or we may be unable to fully respond to your inquiry.
Sources of Personal Information.
We collect personal information directly from individuals, automatically related to the use of our Site or Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, and operators of certain third-party services that we use).
Information collected directly. We may collect personal information about you (such as your name, address, and contact details) directly from you. For example, when you fill out a 'Contact Us' form, signup for our mailing lists, register for events we host or sponsor, register for an account, post comments on our Sites, or otherwise provide us information through the Sites, we may collect personal information such as:
Automatically-collected information. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the Services or visit our Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider ("ISP"), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the "Cookies and similar devices" section below.
Information collected from third parties. We may collect personal information about from third party sources, such as public databases, joint marketing partners, social media platforms or other third party platforms. For example, if you choose to link, create, or log in to your Services account with a third-party account (e.g., Google), or if you post information or engage with us on third party platforms we may collect personal information about you related to that third party platform or account. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.
Categories of Personal Information We Collect.
Certain laws, such as the California Consumer Privacy Act ("CCPA") requires that we disclose certain information about the categories of personal information that we collect about individuals. While the information we collect varies depending upon the circumstances, such as our interactions with you, we may collect the following categories of personal information (subject to applicable legal requirements and restrictions):
Certain laws, including the EU General Data Protection Regulation ("GDPR"), require that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other similar laws), we process personal information for the following legal bases:
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes for Using Personal Information. The purposes for which we may process personal information will vary depending upon the circumstances In general we use personal information for the purposes set forth below, and where GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases):
Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and services, and for similar research and analytics purposes. Additionally, we use third party analytics to gather anonymous data on user behaviour. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.
Data for Predictive Purposes (Reticle)
At Reticle’s request, we may obtain past media data from prospective clients looking to utilize theReticle service/platform. This past media data may contain information related to the prospective client’s past media campaigns, including impressions, clicks and conversions, but would only contain log level data and would not contain any personally identifiable information. For example, Reticle would only be in receipt of hashed IDs from Google, as well as located-based information, which allows Reticle’s to view a conversion path.
Should any of the past media data received above contain any sensitive information, such as spend data or fees, Reticle will permanently delete this information upon receipt (and without keeping a copy on record), prior to analyzing the data for its predictive purposes. Reticle will not store or repurpose the provided data for any other application or use.
Disclosure of Personal Information
In general, we disclose the personal information we collect as follows:
Aggregate and De-identified or Anonymous Data. We may share aggregate, anonymous or de-identified data with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Categories of Personal Information Disclosed. Certain privacy laws (such as the CCPA) require that we disclose the categories of personal information that we may disclose for a business purpose. (Further descriptions of the categories of personal information are provided above, in the Information We Collect section). In general, we may disclose the following categories of personal information in support of our business purposes identified above:
Categories of Personal Information Sold. The CCPA defines a "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation from such third parties, we do disclose or make available certain categories of personal information to third parties, in order to receive certain services or benefits from them (such as when we allow third-party tags to collect browsing history and other information on our Sites to improve and measure our ad campaigns), including:
Cookies and Similar Devices
Like many websites, we use cookies to recognize you when you return to our website so that we can provide you with a customized experience. We may also use pixels, JavaScript, log files and other mechanisms to gather information about your use of our Site.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. See our Cookie Policy for more information.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
Third-Party Analytics. We also use automated devices and applications, such as Google Analytics (more info here) to evaluate use of our Services. We use these tools to gather non-personal information about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.
Do-Not-Track Signals. Our Site does not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies) and set out in our Cookie Policy.
Interest-based Advertising
We work with third-party ad networks, analytics companies, measurement services and others ("third party ad companies") to manage our advertising on third-party sites, mobile apps and online services. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device's geolocation information. This information is used to provide you more relevant ads and content and to evaluate the success of such ads and content.
For more information about third-party ad networks and to opt-out of interest-based ads from many ad networks go to:
International Transfers
Hotspex Media Inc is headquartered in Toronto, Canada and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
If you are in the European Economic Area, and we process your personal information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a "third country"), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of personal information when transferred to a third country. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us as set forth in the "Contact us" section below.
Your Choices and Rights
Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information, please send your request to privacy@hotspexmedia.com. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails or emailing privacy@hotspexmedia.com. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
Additional Information for Certain Jurisdictions. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy and data protection laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this privacy notice:
Security
We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security.
Retention
As a general rule, we retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant personal information of clients and Site visitors for at least three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others. Our clients instruct us on how long to retain Client Data, which we handle as a data processor.
Information About Children
The Hotspex Media site is not intended for minors under the age of 16. We do not knowingly or specifically collect information about minors under the age of 16. If you believe we have unintentionally collected such information, please notify us at privacy@hotspexmedia.com, so that we can delete this information from our servers.
Changes to our Privacy Policy
From time to time, we may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. We will place a notice online when we make material changes to this the Policy. Additionally, if the changes will materially affect the way we use or disclose Information, we will notify you in advance of the change by sending a notice to the primary email address associated with your account or by posting a notice on our Site. We encourage you to periodically review this Policy for the latest information on our privacy practices.
Contact Us
If you have questions or concerns regarding the way in which your personal information is being processed or this Policy, please email us at privacy@hotspexmedia.com or reach out to Hotspex Media using the contact information below:
Hotspex Media, Inc.
40 Eglinton Avenue E #802
Toronto, ON M4P 3A2
Additional Information for Individuals in Certain Jurisdictions
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA").
California Residents' Rights. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
California residents may make a Request to Know up to twice every 12 months, at no charge. We will respond to verifiable requests received from California residents as required by law.
Submitting Verifiable Requests. Requests to know and requests to delete may be submitted by email at privacy@hotspexmedia.com
We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.
INDIVIDUALS IN THE EUROPEAN / EUROPEAN ECONOMIC AREA
This section explains the right that data subjects in the European Union / European Economic Area ("EEA") have pursuant to the GDPR.
Rights under the GDPR. Individuals in the EEA have the below rights with respect to their personal information.
Submitting a GDPR Request. Please contact us as set out in the Contact Us section below to exercise one of these rights. If we receive any requests from individuals related to the Platform Data, we will forward the request to the relevant clients.
