PRIVACY POLICY

Last Update: 10/27/2023

Welcome to Indivizio.com. This website is owned and operated by Pathway Ventures, LLC d/b/a Indivizio (“Indivizio,” “Company,” “we,” and “us”). We provide solutions for advertisers, platforms, and marketers through a wide range of consumer analytics products designed to assist our Clients in maximizing their marketing efforts and brand recognition through an understanding of their audience, including their customers. Our services include promotion of our Clients products, services, and web presence through direct mail, email, display, and third-party marketing channels. This policy is not provided for our Clients, whose information collection, storage, and use are governed by their contracts with us. This policy is not provided for employees or prospects, as our policies governing our internal employment practices are governed by a separate policy.

This Privacy Policy is for consumers who visit or use our, or our Clients’ websites, email, or other web property where our technology is being used. It describes what personal information we collect; how we use that Personal Information; how and to whom we disclose and process Personal Information; how we secure Personal Information; and your ability to contact us with your choices regarding your Personal Information.

Please review this policy closely, as we provide services to our Clients and do not have a direct relationship with consumers. We do not control the privacy policy or practices of our Clients or other parties that consumers may engage and provide information to, including those of our Clients. We encourage you to read all legal notices posted on any website that you are visiting or providing information to include the Terms of Use, Privacy Policy, and other disclosures and disclaimers. By reviewing these posted policies, you will have an understanding of the privacy practices of those parties and the rights you may have to direct, limit, or change the parties to whom your information is collected, used, shared, and stored, including your Personal Information.

INFORMATION WE COLLECT.

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (collectively, “Personal Information”), including:

• Identifiers, which may include your name, physical address, email address, phone number, IP address, mobile number, or other similar identifiers.
• Commercial and Customer Information, which may include your visit to one of our client’s websites, purchase of products or services from our clients or third-parties, email interactions, including opening and linking, profile information relating to your interests, internet usage, search history, feedback information, communication preferences, customer service and communication history.
• Internet or other Electronic Network Activity Information, which may include your IP address, log data, analytics data, device ID, cookie ID, and other data collected through pixels, cookies, web beacons, JavaScript, and similar technologies on our and third-party websites. This may also include your browsing history, search history, and your interaction with a website, app, or advertisement.
• Geolocation Data, which may include your IP address, and that will provide us your general geographic location at the time you viewed our client’s website. Through our contractors and service providers, we may be able to collect your precise geo collection or that of the device you are using when our technology is activated.
• Audio, Electronic, Visual, or similar Information, where permitted by law, we may record phone calls between us or our customer service providers. We may also implement technology which tracks and captures your browsing and use of Services while on our or our client’s website.
• Professional or Employment-Related Information, we may collect such information when verifying your identify, including the business or organization you are employed by or represent, your title with that business or organization, and information relating to your role with the business or organization.
• Demographic Information, which may include your age and date of birth.
• Publicly Available Information, which may include property ownership, DMV records, and any Personal Information available from government websites and files.
• Inferences Drawn from other Personal Information or Data, means we use all of the information we collect from you and that which we collect from third-parties who have collected information from you to draw an inference about interests and preferences to make an analysis of what marketing, products, or services you are interested in based on our and third-party’s analysis of your trends and this may include making a profile of you which includes all information we or they have collected in order to provide our Services.

HOW WE COLLECT INFORMATION.

Information Collected Directly. We collect Personal Information in a variety of ways. We may collect your Personal Information when you visit our Website, contact us via message or email, or respond to our marketing. We may link or combine information collected from you with information we receive from third-parties, as well as information we collect automatically through our technology. We may also combine, or link information collected by us with information we receive from third-parties or through our or third-party tracking technologies.

Information Collected Through Our Technology. Your Personal Information is collected when you visit or interact with a website or email using our technology, which may include the Indivizio Pixel, other pixels, cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies provided by third-party service providers and contractors which automatically or passively collect Personal Information about you and your interactions with our respective clients’ websites and emails. To the extent required by applicable law, we will obtain your consent before using these tools. We use the following technology in our collection of information:

• Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third-parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information from you when visiting a web property which contains our technology to provide our Services. These Technologies are small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with a web property using our Services.
  • Cookies. Cookies are small text files placed in device browsers to store the preferences of the person using the device or browser. These text files do not necessarily contain Personal Information about you, but may use an identifier which will allow our contractors and service providers to match that id to Personal Information they have collected elsewhere.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the website. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded and your engagement with a web property.
  • Indivizio Pixel. This is a pixel tag (commonly known as a web beacon or clear GIF) and is an invisible 1×1 pixel that is placed on our client’s web property and in their emails. When you visit such a page or open an email, the Indivizio Pixel tag may generate a generic notice of the visit and permit us, our clients, our service providers, or contractors to read cookies already placed on your browser. Pixel tags and cookies are used together to anonymously track activity on a website by a user or a device. If you disable cookies, then pixel tags detect an anonymous website visit instead. It also creates an ID which we can provide to third-parties who may be able to associate the ID with your Personal Information.
  • Computer or Device Information. We automatically collect your Internet Protocol ("IP") address or other unique identifier or information from the computer, mobile device, tablet you use to access the Websites, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the Websites.
  • Usage Information. We may collect information about your use of our client’s website or email. We collect the date and time you visit the websites, the content, areas or pages of the websites that you visit, the website or app from which you navigated to the websites, the page or app you visit after leaving the websites, the amount of time you spend viewing or using the websites, the number of times you return to the websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites.
• Use of Third-Party Analytics and Technologies. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see: https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out, please see: https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here: https://tools.google.com/dlpage/gaoptout/.
• Information from Third-Party Service Providers and Contractors. Through our technology, we are able to obtain various cookie IDs from your computer, which we provide to third-parties including service providers and contractors who use such IDs to correlate the same to your Personal Information and provide such information back to us. The Personal Information includes all categories of Personal Information set out in the first section of this Policy including, but may not be limited to, your name, username, demographic information, postal address or contact information, location, interests, and online activity.

Information Collected From Third-Party Sources. We may acquire Personal Information from other sources as follows:

• Service Providers. We use third-party service providers to support our Services and business processes including without limitation, identifiers, internet and electronic network activity, general geo location, and inferences.
• Third-parties. We obtain Personal Information about you from third-party sources, including commercially available sources, data brokers, data aggregators, and public databases as well as companies that license or sell your information to us. This information may include your name, general geographic information, IP Address, email address, and publicly-observed data.
• Combining Information. We may combine the Personal Information we receive from you, third-parties, service providers, and information we automatically collect through our technology and Services, as well as information collected from other online or offline sources, including from third-party data sources. This will provide us with a profile of you which we may be able to use for provision of our and our client’s services to you, as well as identify other products and services that may interest you. We may expand into other marketing avenues in which to market relevant ads to you. For example, we may combine information to obtain your email address, your interest, and use this information to provide relevant product and services marketing via email to you.

HOW WE USE YOUR INFORMATION.

• Use of Information. We use the Personal Information we collect from and about you for any of the following business purposes:
• Providing Services. Our services include providing your email and other Personal Information to our Clients. It may also include providing an analysis of your interests and dislikes, what offers you are more likely to respond to, or what marketing vertical you are more likely to respond to.
• Target Marketing. We may create and provide defined audience segments based on certain demographics or actual or inferred interests or preferences. This may include uses of third-party data and analysis which correlates our information through de-identification techniques such as hashing along with online cookies and other identifiers.
• To analyze, improve, operate, and maintain our Services and systems, or develop new products, services, or marketing.
• Marketing Services. To obtain and pass information, products, or services that you have requested or may be of service or interest to you from us to third-parties, and this includes passing your information on to our clients who provide the products and services to communicate with you directly.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you, us, our clients, or service providers, or third-parties, involving the services or products you or they have requested.
• To provide you and other users with customized content, targeted offers, and advertising on the Websites, or across other websites, mobile applications, social media, or online services, or via direct mail, email, and/or telemarketing regarding offers, contests, events, news, programs, and other related and unrelated services and products that we believe may be of interest to you.
• To determine the effectiveness of our and our client’s marketing programs, including use of your data in an aggregated non-specific format for analytical and demographic purposes. Pursue legitimate interests, such as direct marketing, research, and development (including marketing research), network and information security, fraud prevention, and measure interest and engagement in the Services.
• Product Development. Develop new products and services, or improve our products and Services, and ensure internal quality control and safety.
• Verify individual identity when necessary, carry out audits, or prevent prohibited or illegal services, or security protocols; Communicate with you about activities on the Services, changes to our agreements, and prevent and prosecute potentially prohibited or illegal activities.
• Legal Compliance. Comply with our legal obligation.
• Interest-Based Advertising. We may use third-parties to measure and target advertisements on our or our client’s behalf that are tailored to your online interests or improve our and our client’s marketing efforts. To facilitate these activities, we and third-parties use cookies, web beacons, pixel tags, and similar technologies to collect certain data and other information about your online activity. We also may display interest-based ads through social media platforms or websites. These tools allow us and our clients to personalize our ads based on your shopping experience, without having to share your Personal Information with these social media platforms.

WHO WE DISCLOSE, SHARE, AND SELL YOUR PERSONAL INFORMATION TO. We may disclose, share, and sell (collectively “disclose”) your Personal Information as described below.

• Clients. We disclose your Personal Information to our Clients, which may include third-party ad networks and advertising clients, to deliver advertising and personalized content on our services, on other websites and services, and across other devices. This information may be used to provide and perform targeted advertising as well as to provide advertising-related services such as reporting and analytics.
• Third-Party Service Providers and Contractors. We disclose your Personal Information with companies that compile and license or resell consumer information for use in marketing and analytics including advertising networks, platforms, and analytics providers.
• Parent and Affiliated Companies. We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.
• Service Providers. We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.
• Third-Party Contractors. We disclose and share your Personal Information with third-parties who provide us additional Personal Information about you to provide Services to our Clients.
• Sale or Transfer of Business or Assets. We may disclose your Personal Information as part of our sale of assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. If we file for bankruptcy or reorganization, information we have collected about you may be considered our asset and may be included in the assets transferred.
• Marketing Vendors and Other Third-Parties. We may disclose your information to third-parties who provide display and/or email services or other third-party vendors we use who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for our and third-parties use and to manage and improve our Services and our Client’s advertising campaigns.
• Compliance with Laws. We may disclose your Personal Information to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclose and share your Personal Information to third-parties to assist us in compliance with Laws.
• Enforcing Our Rights. We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes with clients, third-party service provides, and other third-parties or contractors, who provide you with the product or service which you have requested or to protect the security of our Websites, servers, network systems, and databases, and enforce our contractual rights with these parties.
• Aggregate or Anonymous Non-Personal Information. We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.

YOUR CHOICES AND OPTING OUT.

• Cookies, Tracking Options, and California Do Not Track Disclosures. We, third-parties, and service providers place Cookies and Tracking Technology on our Client’s website and emails. You may decline or adjust these technologies through your device or Internet browser settings to limit certain tracking or to decline cookies. Please note that by doing so, you may not be able to use certain features on websites. Please refer to your device's settings or your Internet browser's "Help" section for more information on how to delete and/or disable cookies or to control your tracking preferences.
• Interest-Based Advertising. You have choices for receiving more relevant advertising on the Websites or across other websites and online services, to learn more about these choice please see relevant articles at: http://www.aboutads.info/choices/, http://www.networkadvertising.org/choices/ or for your mobile device, please see: http://www.aboutads.info/appchoices. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/. Your mobile device may also allow you to adjust your privacy and advertising settings to control advertising. Even if you opt-out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third-parties.
• Unsubscribing from Our Marketing Communications. We provide our customers, as well as consumers, with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. If you receive marketing communications from one or more of our affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
• Third-Party Communications. Any third-parties to whom we have disclosed, shared, or sold your information may have their own privacy policies, which describe how they use and disclose your information and your choices. We encourage you to visit the websites of those third-parties.

CHILDREN'S PRIVACY.

We do not direct market our Websites to children under the age of 16. We do not knowingly collect any Personal Information from children under the age of 16. If we learn that a child under the age of 16 has provided personally identifiable information to the Websites, we will use reasonable efforts to remove such information from our files.

DATA SECURITY.

We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of information, communications, and data to us or through our Website, is at your own risk.

RETENTION POLICY.

We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you, until you request we cease further efforts to provide you such offers, or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. As such, we retain Personal Information for as long as you continue to use our Websites and/or services for the purposes explained in our Privacy Notice. When you discontinue the use of our Websites or services, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes, and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information, or if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.

CHANGES TO OUR PRIVACY NOTICE.

We reserve the right to make changes to this Privacy Notice including collection, use, sale, and sharing of your Personal Information. We do not provide notice of changes except through our posting on this page. We use your information only in the manner described in this Privacy Notice at the time you register your information with us. Please be sure to review this policy each time you communicate or register with us for the latest policy. Your continued use of the Websites and/or Services after we post a change in the Privacy Notice means you accept those changes.

CONTACT INFORMATION.

To ask questions or comment about this Privacy Notice and our privacy practices, contact us:

1. By Mail: 2438 Industrial Blvd #503 Abilene, TX 79605

1. Toll-free Number: 1-866-259-7740

CALIFORNIA RESIDENT RIGHTS.

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right, under certain circumstances, to request information from us regarding the manner in which we disclose certain categories of Personal Information (as defined in the Shine the Light law) to third-parties for their direct marketing purposes. To opt-out of this type of disclosure, please use our online form.

California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020. This Privacy Notice for California Residents supplements the information contained in our primary Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

Additional Personal Information Disclosures.

=   Additional Disclosures on Sales, Sharing, or Targeted Advertising. As further described in the Privacy Notice, we may “sell” or “share” your Personal Information (as those terms are defined by the CCPA to third-parties, subject to your right to opt-out of those sales).

In the last 24 months, we sold, shared (for cross-context behavioral or targeted advertising purposes), or disclosed the Personal Information (for the purposes described in our Privacy Notice) as follows:

• Third-party Business (clients) and Marketing Companies: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
• Online Advertising Networks, Social Networks, and Analytics Providers: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.

We also disclose Personal Information to third-parties at your direction or upon your request, in connection with a service or product you have requested or received; for our corporate business transaction; or to comply with legal or contractual obligations; as described in our Privacy Notice. In the last 12 months, we may have disclosed each category of Personal Information for these purposes.

• De-identified Information. We may receive or process Personal Information to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and do not attempt to re-identify the data, except as required or permitted by law.

California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
• The categories of Personal Information collected;
• The categories of sources of the Personal Information;
• The purposes for which we collected the Personal Information;
• The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;
• The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
• The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.
• RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.
• RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.
• RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. The right to exercise control over our collection and processing of Sensitive Personal Information.
• RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION. The right to direct us not to “sell” your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share, and sell your Personal Information to the third-parties who provide to you the services and products you requested at registration.
• RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
• HOW TO EXERCISE YOUR RIGHTS. Submit your request to exercise one of the privacy rights identified above, as follows:
• Submit your request using our online form; or
• Call 1-866-259-7740

Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code. We may, at times, need to request additional Personal Information from you, taking into consideration our relationship with you and the sensitivity of your request.

We will process requests to opt-out of sales within 10 business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.

Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above, where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

CCPA Stats- 2023

Request to Delete	Request to Know	Request to Opt-Out	Request to Limit
Number Received: 0 Complied: 0 *Denied: 0 Avg Day Response Time: 0	Number Received: 0 Complied: 0 *Denied: 0 Avg Day Response Time: 0	Number Received: 1 Complied: 1 *Denied: 1 Avg Response Time: 8	Number Received: 0 Complied: 0 *Denied: 0 Avg Day Response Time: 0

* Denied Requests: Data was not found in our database