Last Updated: January 1, 2019
Internal Profits collects information, including personal information, as part of our provision of the Services. We collect information in the following ways:
Information Provided Directly by You
Internal Profits collects information directly from you when you choose to provide it to us, our clients, or our partners. For example, Internal Profits collects personal information when you choose to submit it to us by using the Contact Us form (or similar forms) on the Website, or if you contact us via telephone or social media.
Information Automatically Collected from You
Due to the variance in privacy laws from place to place, information collected automatically may or may not be considered personal information where you are.
Information Received from Our Clients
Internal Profits receives information, including personal information, from our clients and third parties to perform the Services. Some of the personal information collected has been de-identified or “scrubbed” in order to render it anonymous.
Internal Profits is in compliance with the online industry’s self-regulatory rules pertaining to the collection and use of non-HIPAA related healthcare information. Internal Profits will only collect sensitive health care information when a user consents or opts in to such collection.
How We Use the Information
Internal Profits uses the information it receives for the following purposes:
- Marketing of our products and services.
- Internal Profits uses the personal information we receive from clients or partners to deliver more relevant marketing communications, and other lawful purposes related to our provision of the Services.
- Internal Profits, our third party service providers, our clients, and our partners gather information about users’ online activities from their interaction with advertisements, across the Sites and other internet sites or mobile apps, and supplement such information with information from clients or third parties (such as parties that perform web analytics) in order to make inferences about users’ consumer and other interests. We then use this information to create customized advertising campaigns for our clients, as well as for other marketing-related purposes.
- Internal Profits may combine information with data collected or received from other sources to create a database of consumer and other data (i.e., “aggregated data”), and to use such aggregated data for a variety of purposes, including for unrelated advertising, marketing, and analytical activities.
- Internal Profits may use your personal information to respond to inquiries or address any comments you may have.
- If you are a customer of Internal Profits, we may use your personal information to create and manage your account, fulfill any contractual obligations we may have with you, or to provide you with information about our Services.
Internal Profits is not responsible for, and, with limited exceptions, does not control, the collection of data from third party sources. If you wish to opt out of the collection of your information by third parties, you must contact those parties directly.
Information Sharing and Disclosure
Internal Profits does not sell information.
Internal Profits may share, transfer, and disclose information to business partners, sub-contractors, advertising networks, analytics providers, and search information providers. Internal Profits may also share your information with third party service providers that we use to help us operate our business (such as cloud hosted services like Google Suite & Amazon Web Services) or perform activities on our behalf (such as sending newsletters or surveys).
Internal Profits may share, transfer, and disclose information to third parties with whom Internal Profits contracts to facilitate our provision of the Services and to perform related services such as web analytics and database management. Internal Profits may share information to track the performance and effectiveness of advertising or marketing campaigns, and for determining contractually-owed payments.
Internal Profits does not share your personal information with unaffiliated third parties without your consent. Internal Profits uses personal information for a number of client-authorized purposes, such as reporting on the effectiveness of advertising campaigns and connecting a user’s online information with offline customer data supplied by the client, and customizing the advertisements delivered to those users. Internal Profits also uses the anonymous types of personal information, such as gender and geographic location, in connection with marketing to other users.
In the event Internal Profits is acquired by or merged with another company, we reserve the right to transfer or assign the information, including personal information, we have collected from you as part of such merger, acquisition, sale, or other change of control.
We reserve the right to use and disclose any information about or relating to you, including any personal information, to third parties without your consent if we reasonably believe that such action is necessary to: (1) comply with a court order, search warrant, subpoena, or other legal process; (2) to comply with legal, regulatory, or administrative requirements of any governmental authorities; (3) otherwise fulfill a government or law enforcement request for information; (4) establish, defend or exercise our legal rights; (5) protect or defend our subsidiaries and affiliates, and all of their respective officers, directors, employees, attorneys, agents, contractors, licensors, and partners, in connection with any actual or alleged legal action, claim or dispute; (6) respond to claims that any posting or other content of the Sites violates the rights of third parties, including, without limitation, providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act; (7) in an emergency, to protect the health and safety of our Site’s users or the general public; or (8) enforce compliance with our Terms and Conditions or other contractual obligations.
Legal Basis for Processing Personal Information
The legal basis for Internal Profits processing your personal information depends on where you are located, the specific personal information, and the context in which the information was obtained.
If you are a resident of the European Union, Internal Profits will typically only collect your personal information where we have your consent to do so, where the personal information is necessary to perform a contract with you, or where the legitimate interests of our processing your personal information outweighs your data privacy interests. Internal Profits may also have a legal obligation to collect and process your personal information in certain situations. Should this arise and we ask you to provide personal information, we will make it clear at the relevant time and advise you as to whether the provision of your personal information is mandatory.
Your Data Privacy Rights
You have certain rights relating to your personal information. These may include the right to request access to the personal information we have relating to you, obtain a copy of that information, or request that that information be erased or corrected. You may also have the right to ask us to restrict how we process your personal information, or to withdraw your consent to our processing of your personal information. As laws differ globally, your privacy rights vary depending on where you are located.
You have the option to opt out of Internal Profits’ direct collection and use of your information by emailing firstname.lastname@example.org. Please note that your opt out choice is applied only to the browser from which you make the choice. You may also opt out of the collection of interest-based advertising data by members of the Digital Advertising Alliance by visiting the Consumer Choice Page at www.aboutads.info/choices, and from members of the Network Advertising Initiative by visiting www.networkadvertising.org/choices.
Internal Profits responds to requests to exercise data privacy rights in accordance with the applicable privacy laws. In situations where Internal Profits is processing your personal information exclusively on behalf of a client, applicable privacy laws may require us to forward the request to our client.
European Union Residents
European Union residents have certain data privacy rights. In addition to the opt-out choice detailed above, European Union residents have the following rights:
- The right to request access to the personal information we have collected from you
- The right to request any inaccurate personal information relating to you is corrected
- The right to request we delete your personal information
- The right to restrict processing of your personal information
- The right to withdraw your consent to our processing your personal information
- The right to request portability of your personal information
The information we collect from you will be transferred to entities located in countries outside of the European Economic Area, including the United States.
California residents have certain data privacy rights. In addition to the opt-out choice detailed above, California residents have the following rights:
- The right to request that Internal Profits disclose:
- What personal information we have collected from you
- What categories of personal information we have collected from you
- What sources we have collected the personal information from
- The purpose we have for collecting personal information
- The categories of third parties with whom the personal information has been shared
- The right to request that Internal Profits delete any personal information we have collected from you (except to the extent Internal Profits requires the personal information to detect security incidents, protect against fraudulent behavior, or comply with a legal obligation)
- The right to opt-out of the sale of your personal information. Internal Profits does not sell information.
- The right not to be discriminated against for exercising any other right described herein.
Retention of Personal Information
Internal Profits takes steps to maintain the security of its network and protect the online and other information in our possession, during both data collection and data storage. For example, our servers are protected by reasonable physical and electronic security measures. Since the internet is not a 100% secure environment, the storage and communication of personal information can never be completely secure. There is a potential that a third party not under the control of Internal Profits may unlawfully intercept or access data, including personal information. We, therefore, cannot and do not guarantee or warrant that information that you transmit to us, or any communications conducted on or through the Website, is or will be totally secure. You acknowledge and assume the risk when communicating with us that the security of your online information may be compromised.
“Do Not Track” Signals
Online Industry Self-Regulation
Internal Profits self-regulates pursuant to the Digital Advertising Alliance’s principles applicable to Interest-Based Advertising, to the extent our activities are covered by such principles. For more information about the Digital Advertising Alliance, the self-regulatory principles and the AdChoices program relating to privacy and Interest-Based Advertising, please see the Digital Advertising Alliance’s website, www.digitaladvertisingalliance.org/. Information about the Network Advertising Initiative’s Code of Conduct and its members can be found at www.networkadvertising.org/.
When communicating with us regarding an exercise of your data privacy rights, please remember that you will need to provide us with information sufficient to allow us to verify your identity so that your request is actionable. You can submit requests to exercise your data privacy rights in any of the following ways:
- Via email to email@example.com
- By calling 480-999-0799
- Via mail to Internal Profits, LLC, 9635 N 7th #9101 Phoenix, AZ 85020 Attn: Legal Department
- By completing the form on our Contact Us Page