What is covered by this Policy?
Invoca (“Invoca” “we” or “us”) provides pay-per-call services, using unique phone numbers and other forms of call tracking used in both online and offline advertising. Using unique phone numbers with personalization components, database management, and our proprietary and confidential systems we provide networks, advertisers, agencies, publishers (directly and indirectly, our “clients”), and consumers with pay-per-call features and services that are unmatched in our industry.
We recognize that privacy is important, and our collection and use of information is limited to what is necessary to create innovative and reliable services for our clients, without compromising the individual privacy of consumers. This policy covers data collected through our website, www.invoca.com and data collected through our services.
What information does Invoca collect about consumers?
When a consumer uses our services, for example, by calling a unique phone number associated with one of our advertiser clients, we will collect their personal information if it is made available to us by the consumer or by a third party. This information includes limited personal data such as the caller’s name, address, phone number and email address. We will not knowingly collect personal information from children under the age of thirteen.
We and our clients, for example, an advertiser, may set up order forms, questionnaires, or other mechanisms through which a consumer may be asked to provide certain information either online or via telephone or other communications medium. Participation is purely voluntary, and any consumer not wanting to participate may decline or terminate contact (e.g., navigate away from the web page or hang up the phone).
If such mechanisms are initiated by one of our clients outside of our services and our clients collect the information themselves, we cannot be responsible for that information, although we will endeavor to ensure that such clients maintain reasonable and appropriate privacy policies.
In addition, we may receive from clients email addresses and telephone numbers of consumers for various purposes, for example, facilitating an outbound marketing campaign. Prior to obtaining any such information, we will require assurances from our clients that such information was obtained rightfully, and we must rely on those assurances in delivering our services.
We provide our clients unique telephone numbers to utilize on a web site, email, mobile or offline promotion. This enables us to both determine what the consumer was looking at when making a telephone call and personalize the experience for that consumer. Our phone servers automatically collect the caller ID results when a consumer calls the number, and we may also occasionally collect other usage information from third-party databases, including the name and/or the address of the caller when available.
In addition, our phone servers use software that may be employed on behalf of an advertiser to record calls. This recorded information may be evaluated in order to determine the quality of that call from the advertiser’s perspective and for training or other purposes. This enables us to identify high-quality calls and collect additional usage data we can use to provide our clients with improved services and sales. We may also use third-party services or technology for the transcription or analysis of such information. In the event we record a call on behalf of an advertiser, we will ensure that call participants are advised of the existence and intent of the recording in a manner consistent with applicable state and federal laws. We are not responsible in any way for the accuracy or validity of the content of any such recordings, and we take no steps to evaluate such accuracy or validity.
While we strongly encourage clients to adopt responsible approaches to marketing, we are not responsible for the information practices of clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from Invoca’s policy.
Reasons for collecting usage information
We may collect usage information when an internet user clicks on a link, creates a lead, initiates a phone call, receives a phone call, makes a purchase on an advertiser’s web site, sends us a text message, receives a text message from us, or makes an inquiry or a purchase during a phone call to an advertiser. We collect this information primarily for the purpose of paying third-parties commissions and also to optimize and personalize the internet and phone user’s experience. If the internet user re-visits the advertiser’s site directly, or if the phone user calls the advertiser using the unique phone number again, Invoca is able to continue to track the user’s activities on the advertiser’s site and compensate the third party that referred the user. We reserve the right to retain all data as long as may be reasonably necessary for accounting and audit purposes.
Like most standard Web site servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. We may use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content.
We also may develop predictive statistical user profiles of consumers’ needs and interests by collecting both internet browsing and online purchase data and phone user data. For improved audience targeting, some Invoca services may use marketing technology to allow advertisers to supplement non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data.
Invoca may collect personal information, such as consumers’ names, physical addresses, email addresses, phone numbers and other information in order to better target campaigns to meet user’s interests and to provide customized experiences. We will share this information only as described herein.
Does Invoca share consumers’ personal information with others?
We do not share consumers’ personal information we have gathered except as described below. Our clients, however, may gather personal information by other means, especially if a consumer completes a transaction with them.
We only share consumers’ personal information with companies or individuals outside of Invoca in the following limited circumstances:
Invoca may also share personal information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of Invoca.
Finally, Invoca may release personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Invoca or others. This includes exchanging information with other companies and organizations for fraud protection.
Can a consumer “opt-out” of providing information?
For consumers accessing our services through the internet, some of our cookies may have an “opt-out” option. This process does not remove the Invoca cookie from a consumer’s system; it simply replaces it with an opt-out cookie that does not contain any unique identifiers.
With regard to phone services, consumers are able to submit their phone numbers to “do-not-call” registries. We will use our best efforts to observe do-not-call registries in any outbound calling campaign we perform or facilitate, provided that consumers who have opted-in to receive such messages, either with a client or with us, shall not be subject to any do-not-call restriction.
Can a consumer access the personal information acquired by Invoca?
Invoca’s services are not directed towards individual consumers, and we are collecting personal information on behalf of our clients to provide them a service. Therefore, we do not maintain a process for an individual consumer to review and/or request changes to any personal information collected.
Except as provided below, we do not maintain a process for an individual consumer to access his or her personal information.
What information does Invoca collect from its clients (e.g., networks, agencies, advertisers and publishers)?
We may collect personal information from all of our clients (e.g., networks, agencies, advertisers, and publishers. The collection of this information is a part of our normal business practices. Advertisers or their representatives will be asked to provide personal information through the sign up and registration process either directly or through a network or agency partner. This information may include name, address, phone number, hours of operation, coverage areas and email address. Additionally, we may collect sensitive personal information such as social security number and tax ID number.
When using our service, clients may enter third party personal information such as other user’s email on the platform. This information is only used to provide the client access to the system and for no other purpose.
How does Invoca use its clients’ information?
Much of the information collected from clients is principally intended for administrative needs (e.g. accounting and performance reporting), for which purpose such data are required.
While we strongly encourage clients to adopt responsible approaches to online marketing, we are not responsible for the information practices of clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from Invoca’s policy.
Periodically we may use clients’ information to communicate via email newsletters or other avenues to offer strategic marketing information and other communications to assist in business related activities. Our clients can elect to opt-out from future communications by clicking on the unsubscribe link in the email.
Except as otherwise agreed, we will keep all personal data provided by individual clients in strict confidence and will treat such data with the same level of respect and care that we treat our own proprietary information and trade secrets. We do not sell, rent, exchange or barter any personal client information to or with any third party for financial gain or marketing purposes. We may, from time to time, provide personal information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services. Examples include an email service provider, marketing solutions provider, and a blog provider. Any third-party vendor so used has agreed to protect the confidentiality of information provided by Invoca.
Invoca may also share information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of Invoca.
Invoca may release information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Invoca or others. This includes exchanging information with other companies and organizations for fraud protection.
Can a client “opt-out” of providing information?
Collecting information from our clients is required as a part of doing business. Invoca’s primary intent in collecting information is for administrative purposes including accounting and reporting. However, we may periodically use information for marketing and communication purposes targeted to our clients. Clients wishing not to receive such communications may do so by informing their designated Invoca representative in writing at any time or by clicking on the unsubscribe link in the promotional communication.
When a client logs on to any browser-based Invoca reporting system, a cookie is placed within their computer. The cookie allows us to validate the client’s identity and maintain the security and privacy of the client’s account data. This cookie does not contain any personal information. It is required to log into Invoca’s reporting systems and there is no method to opt-out of this cookie.
If you are a client, and would like the personal information we hold about you deleted, please contact email@example.com or contact their designated Invoca representative. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. With your consent we may post client testimonials along with their name.
Links to Other Web Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.
How does Invoca protect the security of personal information?
Invoca takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Any data stored on our servers is treated as proprietary and confidential and is not available to the public. We restrict access to personal information to those employees or third parties who have a need to know such information for the purpose of effectively delivering Invoca products and services by means of user login and password requirements. We routinely evaluate our data security practices to identify security threats or opportunities for improvement.
No transmission of data over the Internet or even the phones is guaranteed to be completely secure. It may be possible for third parties not under the control of Invoca to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us.
What are Invoca’s policies regarding children and SPAM?
Our services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with us, and we do not collect personal information from any person we actually know is under the age of 13. If you believe your child has provided Invoca with any personally identifiable data, please contact us at firstname.lastname@example.org to have them removed.
Invoca is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or “Spam” e-mail by Invoca or any of its marketing partners.
Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails about the advertiser.
Safe Harbor Compliance
The European Union (“EU”) maintains strict privacy laws. These rules differ significantly from U.S. laws. To reconcile these differences, the United States and the EU have created a Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from the EU to the United States. The U.S. and Switzerland have created a similar, but separate Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from Switzerland to the United States. Invoca, Inc. complies with the U.S. – E.U. Safe Harbor Framework and U.S – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union and Switzerland. Information regarding both the Safe Harbor Frameworks can be found at: http://export.gov/safeharbor.
November 7, 2011