PRIVACY POLICY

UPDATED 01 July 2019

This Privacy Policy (the "Policy") explains how limelightr Pty Ltd ("limelightr", "we" and "us") use personal information collected through your use of our website(s), products, services and applications (the "Services"). We will always ask your consent before using your personal information for a purpose that isn't covered in this Policy

Personal information is any information we deem may allow the identification of any living individual. This includes both information you explicitly supply to us, for example an email address, and information we collect incidently to provide our Services, for example your browser configuration.

This Policy does not apply to personal information you may provide to third party websites that you access via this website, or information you submit to service providers on this website. This Policy also does not apply to payment information you provide to our payments provider Stripe when completing credit card transactions on this website or when creating a payment account on Stripe's website. Read Stripe's Privacy Policy

1. Fundamental Principles

The good news is we at DigitalMediaSearch won't share your user content with third parties without your consent, except if required by Australian or U.S. court order. There are just four possible cases where information about you leaves our servers:

  • 1. We send your IP Address in isolation to a geolocation service (Maxmind) in order to determine your country of origin and applicable taxes.
  • 2. If you create an account with us protected by 2FA, we send your mobile phone number in isolation to our SMS provider (Twilio) in order to provide two-factor authentication. This number is not used for any other purpose or shared with any additional parties.
  • 3. If you make purchases or receive payments via our Services your payment information will be shared with our payments provider (Stripe).
  • 4. We use Google and Facebook analytics first and third-party cookies to see which pages you visit and later to advertise to you on Facebook and Google owned platforms - see the relevant Google and Facebook policies to understand how your data is handled.

How do you define 'explicit consent'? By 'explicit concent' we mean we will present to you a clear notice on the website such as a pop up or large bold text in a form requesting your permission whenever you are about to send personal information a third party such as a service provider.

Why the exception for court orders? We aren't Batman. We don't have a secret head quarters. We host our data in Australia and the United States and that means we need to comply with US and Australian law. Moreover, there is always a risk that some users will exploit our peer to peer services to facilitate illegal activity, including violating the privacy of other users. Responding to court orders allows us to assist law enforcement in preventing crime and prosecuting those responsible.

2. What do we collect?

Information You Explicity Supply to Us
In order to post user content or raise support tickets with DigitalMediaSearch we require you to register personal information that includes a username, password, email, display name, organisation name (optional) and phone number (optional). This information is required to help secure your data and to give us a way of contacting you if there is an issue with your account or our services.
We also collect any user content you create such as nudge messages, chat messages, pitches and profiles. We need to store this information so we can display it to you and other users later!

Information Collected Incidently
Running a website requires us to collect certain technical information to make sure the site works as planned on your device. The technical information we collect may include your Internet Protocol address (also known as “IP address”) or other device address or ID, web browser or device type, the web pages or sites that you visit just before or just after our website, the pages you view on the Services, and the dates and times that you visit the website.

Cookies
When you use our website we send one or more cookies - small text files containing a string of alphanumeric characters – to your computer. For example, we use cookies to ensure proper navigation between pages on our website and so that you don't have to log in every time you visit the website. limelightr may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services.

Persistent cookies can be removed. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. If you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Sales Analytics
We may track the number of times you view certain pages on our website and the purchases you make to help us improve our services. Using such tracking allows us to suggest related products and see which parts of the website are most useful to customers.

3. How do we use your information?

We use your personal information to improve your experience of our Services, including to:

  • Provide Our Services. For example, we need your IP address to send you website data and we use cookies to save your account login state.
  • Improve Services. For example, by analyzing your page views we can see which types of datasets are most in demand and tailor our marketing strategy to bringing more of those types of datasets to our website.
  • Pay, Charge or Refund You. For example, in order to issue a refund we need to store a record of the original sale including transaction identifiers supplied to us by Stripe.
  • Communicate With You. For example, to let you know of responses to your nudges we need your email address.
  • Protect You. For example, by providing us with a phone number we can better protect your account from hackers (they would need to hack both your phone AND your computer in order to access your account).
  • Enforce Legal Claims. For example, investigating potential violations of our Terms of Use.

4. Google Analytics and Facebook Conversion Pixels

We use the “Custom Audience pixel” of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) on our website. With its help, we can keep track of what users do after they see or click on a Facebook advertisement. This enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes. Please click here if you would like to withdraw your consent https://www.facebook.com/settings/?tab=ads#_=_

Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.

In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website.

Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.

Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.

Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.

You can find additional information on how to install the browser add-on referenced above at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. For the cases in which personal data is transferred to the US, Google has self-certified pursuant to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).

5. Data Security & Retention

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Information. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

If you are a DigitalMediaSearch user, we retain your Personal Information as long as we are providing the Services to you. We retain Personal Information after we cease providing Services to you, even if you close your limelightr account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

6. Changes to Terms

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Information practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Information collected by posting them on our website and, if you are a user, by contacting you through your email address.