PRIVACY POLICY
ENGINE GROUP INC. USA CORPORATE PRIVACY POLICY
Effective Date: December 19, 2019

Engine Group Inc.  (“Engine ” or “we”) respect your right to privacy. This Engine USA Corporate Privacy Policy (“Privacy Policy”) explains the information we collect and how we collect, share and use personal information.

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY CAREFULLY.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy. If you have not done so already, please also review the Engine Group Terms of Website Use.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to the www.enginegroup.com (the “Site”).  This Privacy Policy does not apply to information that is collected by any of our product websites that have their own privacy policies or to any third-party website that you may access through the Site.

INFORMATION WE COLLECT & HOW WE COLLECT IT

Engine Group collects information from or about you when you use the Site.  This site is directed to our clients and partners, which are businesses. When information identifies or can be reasonably linked to you, we refer to it as “personal information.”

Information you give us: Engine Group collects information that you choose to provide to us when you complete the Contact us information which asks for: your name, email address, company name and the message that you choose to send us.

Automatically-collected information: When you use the Site, we automatically collect information about how you access and use the Site using cookies and other data collection technology (as described in Section 3 below).

Usage Information: We collect information about your activity on the Site, such as date and time you logged in, features you’ve been using, search queries, webpages you viewed and referring webpage address.

Device information: We collect information from and about the computer, tablet or mobile telephone (“Device”) you use to access the Site, including hardware and software information such as IP address, device ID and type, advertising IDs, browser type and language, operating system, time zones, information on your wireless and mobile network connection and identifiers associated with cookies or other technologies that may uniquely identify your Device or browser.

Information from other sources: Engine Group may collect information about you from third parties.

When you Connect with Social Media though the Site: The Site links with social networking platforms (e.g., “Share to Twitter” button).  When accessing the Site through a social media account, we may (depending on the applicable social media account privacy settings) automatically receive information (including personal information) from the social media platform.  Engine Group may collect and use this information for the purposes described in this Privacy Policy.

Through Service Providers: Third parties that assist us with our business operations also collect and use information through the Site and may share the collected information with us.  For example, our service providers collect and share information with us to analyze the performance of the Site, detect and prevent fraud, conduct a special offer or other promotion or to improve user experience.  Engine Group may from time to time supplement the information that we collect from you with information that we rent or buy from third parties.  We may combine the purchased or rented information with information that we already have from or about you.

With your consent:  we may from time ask you for your consent to collect information that is not described in this Privacy Policy.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Site.

The Site uses the following cookies:

Strictly necessary cookies, which are required for the operation of the Site.

Analytical/performance cookies, which allow Engine Group to recognize and count the number of visitors, learn how visitors navigate the Site and improve the Site.

Functionality cookies, which Engine Group uses to recognize you when you return to the Site.

Engine Group also uses web beacons (also called pixel tags or clear GIFs).  A web beacon is computer code that communicates information from your Device to a server.  Some of Engine Group’s content and emails may contain embedded web beacons that allow a server to read certain types of information from your Device, allow us to count the number of people who have viewed content, to know when you opened an email message and the IP address of your Device.   Web beacons help Engine Group develop statistical information to provide better and more personalized content.   To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Engine Group also uses Google Analytics to collect information.  Generally, Google Analytics does not identify individual users.  To learn more about Google Analytics practices, please visit www.google.com/policies/privacy/partners/.

 

How does Engine Group use cookies and other data collection technology?

Some data collection technology is deployed by Engine Group when you visit the Site.

Cookies and other data collection technology help us improve your experience of the Site by, for example, compiling statistics about use of the Site and helping us analyze technical and navigational information about the Site and to detect and prevent fraud.

We also may use cookies and other data collection technology to collect information from the Device that you use to access the Site, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

HOW WE USE YOUR INFORMATION

To provide the Site to you
Respond to your requests, such as when you sign up to receive news about Engine Group.
Communicate with you about Engine Group.

To improve the Site
Analyze users’ behavior to improve the Site and its content.
Develop new Site features.

To prevent and detect fraud or other unauthorized activities
Analyze information we collect or receive to better understand and design countermeasures against fraud

To ensure legal compliance
Comply with laws applicable to Engine Group
Assist law enforcement
Enforce or exercise our legal rights

HOW WE SHARE YOUR INFORMATION

We share information as follows:

With our service providers and partners
We use third parties to help us operate and improve the Site.  These third parties assist us with data hosting and maintenance, analytics, customer care, marketing, payment processing and security operations If you provide any personal information to an Engine Group partner (and not through the Site), the privacy policy of the partner, not Engine Group, governs your personal information.

With other Engine Group businesses
We share your information within the Engine Group family of businesses to assist us in processing your information, such as data hosting and maintenance, customer care, marketing and targeted advertising, better understanding how the Site are used, securing our data and systems and fighting fraud

For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law
Applicable law may require us or our service providers to disclose your information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).

To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request
We may ask for your consent to share your information with third parties.  When we do, we will make it clear why we want to share the information.

DATA RETENTION

Engine retains data it uses for research purposes for periods determined by our clients, after which the information is removed and discarded. If you have contacted us or provided PII to Engine to be contacted or joined our mailing list, we will retain your information for as long as you’re active or as needed to provide you with information.

YOUR CHOICES

We hope that after reading through this Privacy Policy, you agree that Engine is collecting and using data responsibly, and that the cumulative benefits of our work are beneficial to improving the lives of people around the world.. At Engine, our goal is to offer a harmonized online experience with whatever browser you use. Most browsers accept cookies by default but in certain cases, like Safari, our cookies are blocked by default by the browser settings. California and EU data subjects have additional access, deletion and opt-out rights as described below. In general, we treat California data subjects that opt-out via the methods described below as having opted out of Engine’s sale of their personal information (to the extent that Engine sells data under California law). 

Upon request, Engine will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your PII by contacting us at dpo_US@enginegroup.com. We will respond to your request within a reasonable timeframe. In order to help us to respond promptly to your enquiry or request, please include as much information as you can in your communication with us—such as the reason you believe we hold any of your data, and any other supporting information such as a particular survey or focus group you took part in, or the title of any email you may have received, or the phone number you may have received a call from.

Engine utilizes the services of third parties that are a member of the Network Advertising Initiative (“NAI”) and adhere to its Codes of Conduct. You can learn more about the NAI by visiting www.networkadvertising.org. NAI offers an online opt-out platform to allow Internet users to express their choices and provides general information related to Interest Based Advertising. You may opt-out of Engine by clicking the opt-out link above and selecting Engine. If you wish to opt out of IBA in general, click here, or if located in the European Union click here. Please note you will continue to receive generic ads if you opt-out.

MOBILE DEVICE CHOICES

For mobile websites, you can delete our cookie via the browser settings. For mobile apps, you can typically limit ad tracking within the settings function. On most Android devices, in the “Ads” menu, you can opt out of receiving IBA, or reset your advertising ID. On most Apple iOS devices, you can use the Ad Tracking settings to limit receipt of IBA or reset your device’s Advertising Identifier. Please note that your experience may be different depending on your individual device and service. In addition to using the options above, you may also uninstall the application from your device. If you download a mobile application, it may use advertising to fund its development and maintenance of its software in iOS and Android. In situations involving applications, if you do not want to receive IBA you will need to remove those applications from your device.

CALIFORNIA DATA SUBJECTS

The California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information).

You may access those rights with respect to Engine by sending us an email to dpo_US@enginegroup.com or calling us via our toll-free California data subject hotline at 833-457-0281. We will take steps to confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days. Engine does not discriminate against you if you exercise any of the above rights. Please note that we may not be able to honor one or more of these rights if doing so would violate applicable law.

The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.

We may take reasonable steps to verify your request.  We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.

You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. We may require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.

SAFEGUARDING INFORMATION WE COLLECT AND USE

The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take reasonable physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure.

PRIVACY OF CHILDREN

We are committed to protecting the privacy of children. In general, neither Engine’s website nor Engine online activities with its clients are intended or designed to knowingly attract children under the age of 13.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. When we do, we will post the change(s) on our website. We encourage you to periodically review this page for the latest information on our privacy practices.

TERMS & CONDITIONS DURING YOUR VISIT TO THE ENGINE WEBSITE

The place of performance for this website is New York. Engine makes no representation that materials at this site are appropriate or available for use outside of the United States and access to them from territories where their contents are illegal is prohibited. You are responsible for compliance with local laws in relation to the use of this site outside the United States. The use of this site does not establish any joint venture, partnership, employment, or agency relationship between you and Engine. The Choice of Law is New York. You hereby consent to the jurisdiction and venue in the state and federal courts in New York, NY. Please be aware that Engine may provide links to other websites, which if you click on them may collect personal information about you. The information practices of those third party websites linked to Engine are not covered by this Privacy Statement.

Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section. As a visitor to this website, YOU UNDERSTAND AND CONSENT THAT ANY DISPUTE CONCERNING PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose information you supply to us with regard to: (a) the purposes for which such third party’s information has been collected; (b) the intended recipients or categories of recipients of the third party’s information; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. You agree that the English-language version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

Your use of this website constitutes your agreement to indemnify Engine and its affiliated entities and to hold them harmless from any and all claims and expenses, including attorney’s fees, arising from your use of this website.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

QUESTIONS ABOUT THIS PRIVACY POLICY?

If you have any questions, comments, or concerns regarding this Privacy Policy or the Site, please contact us at dpo_US@enginegroup.com or

Engine Group, Inc.

Attn: Privacy

261 Madison Avenue, Floor 4

New York, New York 10016

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