What is covered by this Policy?
PI Revenue ("PIR" "we" or "us") provides pay-for-performance services matching product and service marketers with media outlets and agents and brokers of media outlets, 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, marketers, agencies, media outlets and publishers (directly and indirectly, our “clients”) with pay-for-performance 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.
CONSUMER PRIVACY
What information does PIR collect about consumers?
General
When a consumer calls 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.
User-supplied Information
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 these mechanisms are included in our services prior to the time a consumer is connected with our client, any information collected by PIR will be subject to this policy.
If such mechanisms are instead 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.
Usage Information
Web services
When a consumer responds to or views an internet advertisement served by a PIR client (such as through third-party web sites or email solicitation) or visits a PIR site, we may send one or more cookies (an anonymous, unique identifier) to the consumer’s computer to uniquely identify that consumer’s browser. Like most companies doing business on the internet, we use cookies to improve the quality of our services by storing user preferences, tracking user trends, determining how our services are used and navigated. Most cookies are automatically deleted at the end of a session at the Web Site. While we may use what are commonly described as “persistent” cookies that remain on a specific browser after termination of a session, any consumer may set their browser to refuse cookies or automatically clear cookies after termination of a session.
Phone services
We provide our clients unique telephone numbers to utilize on a web site, email 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 usage information when a consumer calls the number, including caller ID results, name of caller, and 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 at the advertisers request in order to determine the quality of that call from the advertiser’s perspective. 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. The entire process is automated and involves no humans, although calls may be listened to for quality control and other purposes. 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.
Except under express written request by a client which shall be subject to approval by PIR, we do not expose our clients to any personally identifiable information derived from telephone calls, including, but not limited to, caller ID results, name of caller, address of the caller, and any recorded call data. 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 PIR’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, PIR 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 PIR services may use marketing technology to allow advertisers to add non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data.
PIR 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, but will not share this information with third parties. For these purposes, we will not collect through any means credit card data or social security numbers.
Does PIR share consumers’ personal information with others?
We do not share consumers’ personal information we have gathered with our clients. 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 PIR in the following limited circumstances:
PIR may also share personal information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of PIR.
Finally, PIR 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 PIR 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 have an "opt-out" option. This process does not remove the PIR cookie from a consumer’s system; it simply replaces it with an opt-out cookie that does not contain any unique identifiers. If this site provides such a process it is detailed below.
Some of our cookies do not have an "opt-out" option, but consumers always have the option of blocking the use of cookies by changing a setting in their Internet browser.
PIR does not maintain a process for an individual consumer to opt-out of a PIR ad serving cookie. However, any consumer may set their browser to refuse cookies or automatically clear cookies after termination of a session.
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 PIR?
PIR’s services are not directed towards individual consumers, 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.
CLIENT PRIVACY
What information does PIR collect from its clients (e.g., networks, agencies, advertisers and publishers)?
We 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, including name, address, phone number, hours of operation, coverage areas, email address, and social security number, tax ID number, etc.
In addition, we will use cookies, log files and unique phone numbers to optimize and personalize the clients' experience and allow us to monitor those services and usage patterns.
How does PIR 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 PIR’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.
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 will never 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 such information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services. Any third-party vendor so used has agreed to protect the confidentiality of information provided by PIR.
PIR may also share information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of PIR.
PIR 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 PIR 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. PIR’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 PIR representative in writing at any time.
When a client logs on to any browser-based PIR 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 is required to log into PIR’s reporting systems and there is no method to opt-out of this cookie.
GENERAL
How does PIR protect the security of personal information?
PIR 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 PIR 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 PIR 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.
How are changes made to the Privacy Policy?
We may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that everyone is aware of the information we collect, how we use it, and under what circumstances we disclose it. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by PIR prior to the effective date of the policy change.
What are PIR’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 PIR with any personally identifiable data, please contact us at legal@ringrevenue.com to have them removed.
PIR 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 PIR 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.
Contact Us
For more information or if you have questions or concerns regarding the PIR Privacy Policy, please contact us at infol@pirevenue.com or you can send correspondence to the following address: Privacy, P.O. Box 2118, Santa Barbara, CA 93120.
Policy Updated:
January 27, 2010