Invoca, Inc. (“Invoca”) owns and operates a proprietary marketing technology platform. Using unique phone numbers with personalization components combined with database management, Invoca provides networks, advertisers, agencies, publishers (directly and indirectly “Clients”), and consumers with marketing automation services (the “Services”).
Privacy is important to Invoca and any information that is collected or used is limited to what is necessary to create and maintain innovative and reliable Services without compromising the individual privacy of consumers. This policy covers data collected through Invoca’s corporate website (www.invoca.com) and data collected through the Invoca Services.
Invoca has received TRUSTe’s Privacy Seal signifying that both this privacy statement and Invoca’s practices have been reviewed for compliance with the TRUSTe program. Invoca’s compliance with the TRUSTe program is viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification covers only Invoca’s collection, use and disclosure of information collected through Invoca’s corporate website (www.invoca.com) and through the Invoca Services. The use of information collected through Invoca Services shall be limited to the purpose of providing the service for which the Client has engaged Invoca, Inc.
If you have an unresolved privacy or data use concern that is not addressed here satisfactorily, please contact TRUSTe here.
What information does Invoca collect from consumers?
In general, when a consumer uses the Invoca services by visiting the website or by calling a unique phone number associated with one of our Clients, Invoca collects that consumer’s personal information if it is made available 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. Invoca will not knowingly collect personal information from children under the age of eighteen.
Invoca or its Clients may also 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 communication medium. Invoca will collect such consumer-supplied information. If, however, such communications are initiated by one of Invoca’s Clients and the Client collects the information, Invoca cannot be responsible for that information, though Invoca does endeavor to ensure that its Clients maintain reasonable and appropriate privacy policies. Participation in any of these communications is purely voluntary; any consumer not wanting to participate or provide information may decline or terminate contact by navigating away from the web page or hanging up the phone.
Invoca provides Client’s with unique telephone numbers to utilize on websites, emails, mobile or offline promotions. This enables Invoca to both determine what the consumer was viewing when making a phone call and also personalize the experience for that consumer. Invoca’s phone servers automatically collect the caller ID results when a consumer calls a number. Invoca may also collect usage information from third-party databases, including the name, address and/or geographic location of the caller when such information is available.
In addition, Invoca’s phone servers use software that may be employed on behalf of a Client to record calls. This recorded information may be evaluated in order to determine the quality of that call from the Client’s perspective and for training or other purposes. The recorded information also enables Invoca to identify high-quality calls and collect additional usage data which help improve the Services and boost sales for Clients.
Invoca may also use third-party services or technology for the transcription or analysis of such recorded information. In the event that Invoca records a call on behalf of a Client, Invoca 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. Invoca is not responsible in any way for the accuracy or validity of the content of any such recordings, and takes no steps to evaluate such accuracy or validity.
While Invoca strongly encourages Clients to adopt responsible approaches to marketing, Invoca is not responsible for the information practices of Clients or their partners. The collection, use, and disclosure of information by Clients and their partners are subject to their respective privacy policies, which may differ from Invoca’s policy.
What are Invoca’s reasons for collecting usage information?
Invoca collects 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 a Client’s website, sends Invoca or a Client a text message, receives a text message from Invoca or a Client or makes an inquiry or a purchase during a phone call to a Client. Primarily, Invoca collects this information for the purpose of attributing calls back to the originating ads or paying commissions to third parties and also to personalize the internet or phone user’s experience. If the internet user revisits the Client’s site directly or if the phone user calls the Client using the unique phone number again, Invoca is able to continue to track the user’s activities on the Client’s site and compensate third parties that referred the user. Invoca reserves the right to retain all data as long as may be reasonably necessary for accounting and audit purposes.
Like most standard Website servers, Invoca uses log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. Invoca 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 do link this automatically collected data to other information we collect about you.
Invoca 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 as well as to provide the Services to Clients. Invoca will share this information only as described herein. Invoca will retain this data on behalf of Clients for as long as needed to provide the Services to that Client. Invoca may also retain and use personal information as necessary to comply with any legal obligations, resolve disputes and/or enforce agreements.
Does Invoca share usage information with others?
Invoca does not share consumers’ personal information with companies or individuals outside of Invoca except as described below:
- Invoca obtains consumer consent by requiring consumers to opt-in prior to Invoca sharing information with Invoca’s trusts third parties.
- Invoca provides such information to its Clients to enable them to better provide consumers with information about products or services about which the consumer may be inquiring.
- Invoca may share personal information with our affiliates and other third parties to provide consumers with goods or services requested by them.
- Invoca may share personal information in connection with the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Invoca. In this case, consumers will be notified via a prominent notice on our website of any change in ownership or uses of consumer’s personal information, as well as any choices consumers may have regarding their personal information.
- Invoca may release personal information when it believes such release is appropriate to respond to a subpoena or to otherwise comply with the law, enforce or apply Invoca’s Terms of Service 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?
With regard to phone services, consumers are able to submit their phone numbers to “do-not-call” registries. Invoca will use its best efforts to observe do-not-call registries in any call campaign it performs or facilitates. However, consumers who have opted-in to receive such messages, either with a Client or with Invoca, 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 toward individual consumers. Invoca collects personal information only on behalf of our Clients to provide them a service. Invoca may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. If you are a customer of one of Invoca’s Clients and would no longer like to be contacted by a Client that uses the Invoca Services, please contact that Client directly as that Client controls such data. Invoca has no direct relationship with the individuals whose personal data it processes. An individual who seeks access to or otherwise seeks to correct, amend or delete inaccurate data should direct such inquiry to Invoca’s Client. If you do contact Invoca regarding such a request, Invoca will respond within thirty days.
What information does Invoca collect from its Clients?
Invoca collects personal information from all of our Clients, which include networks, agencies, advertisers and publishers. The collection of this information is part of Invoca’s normal business practices. Advertisers or their representatives will be asked to provide personal information through the sign up and registration process either directly by Invoca or indirectly through a network or agency partner. This information may include name, address, phone number, hours of operation, coverage areas and email address.
Technologies such as: cookies, beacons, tags and scripts are used by Invoca and our marketing partners, affiliates, or analytics or third party administrative. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 or Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
When using the Invoca Services, Clients may enter third-party personal information on the platform, such as entering another user’s email. This information is only used to provide the Client access to the system and is not used for any other purpose.
How does Invoca use its Clients’ information?
Much of the information collected from Clients is required to be collected for administrative needs, such as accounting and performance reporting. Periodically, Invoca 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. Clients can opt-out from future communications by clicking on the unsubscribe links in such emails.
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 from the advertiser. Invoca is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is Invoca’s policy to prohibit the sending of unsolicited or “Spam” e-mail by Invoca or any of its marketing partners.
Except as otherwise provided, Invoca keeps all personal data provided by individual Clients in strict confidence and treats such data with the same level of care and respect that Invoca treats its own proprietary information. We do not sell, rent, exchange or barter any personal Client information to or with any third party for financial gain or marketing purposes. Invoca may, from time to time, provide personal information to certain third-party administrative vendors for efficient 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 it believes release is appropriate to respond to a subpoena or otherwise comply with the law, to enforce or apply Invoca’s Terms of Service and other agreements or to 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 Clients is required as a part of doing business. Invoca’s primary intent in collecting information is for administrative purposes. However, it may periodically use collected 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 Invoca holds about you corrected, updated or deleted, please contact email@example.com or contact your designated Invoca representative. Invoca will respond to your request to access information within 30 days.
Invoca retains all information for as long as a Client’s account is active or as needed to provide Services to the Client. If a Client wishes to cancel an account or request that Invoca no longer use information to provide the Services, contact firstname.lastname@example.org. Invoca will retain and use a Client’s information as necessary to comply with any legal obligations, resolve disputes and enforce any agreements.
Invoca’s website offers publically accessible blogs or community forums. Any user of the Invoca website should be aware that any information provided in these areas may be read, collected and used by others who access these sites. To request removal of any personal information from the Invoca blog or other community forum, contact email@example.com. In some cases, Invoca may not be able to remove the personal information, in which case Invoca will respond accordingly. Invoca will only post Client testimonials with the Client’s consent to do so.
Links to other websites:
The Invoca website and platform may include links to other websites whose privacy practices may differ from those of Invoca. If a user submits personal information to any of those sites, that user’s information is governed by that third party’s privacy statements. We encourage users to carefully read the privacy statement of any website it visits.
Social Media Widgets:
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. When a user enters sensitive information (such as login information), Invoca encrypts the transmission of that information using secure socket layer technology (SSL). Any data stored on Invoca’s servers is treated as proprietary and confidential and is not available to the public. Invoca restricts 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. Invoca routinely evaluates its data security practices to identify security threats or opportunities for improvement.
No transmission of data over the Internet or 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 Invoca strives to protect users’ personal information, it cannot ensure or warrant the security of any information a user transmits.
What are Invoca’s policies regarding children and SPAM?
The Invoca Services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with Invoca and it does not collect personal information from any person it actually knows is under the age of 18. If you believe your child has provided Invoca with any personally identifiable data, please contact firstname.lastname@example.org to have that user removed.
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 complies with the U.S. – E.U. 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 member countries. Invoca has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view Invoca’s certification, please visit http://export.gov/safeharbor.
February 13, 2015