May 11, 2018

This Privacy Policy describes Collective, Inc.’s dba “Visto” (“we,” “us,” “our”) data practices related to the corporate site www.vistohub.com (“Website”). For information about the data practices of Visto’s services, see the Visto Services Privacy Policy.

Data Collection

We receive personal information via our Website when you voluntarily provide it to us. This personal information includes contact information such as your name, address, email address, and telephone number when you contact us with questions or request services from us. When you visit our website, we also collect “Activity Information,” including but not limited to, IP address, web pages visited on the Website, links clicked, operating system and browser type and mobile device identifier. Activity Information is collected through cookies (i.e. small text files placed on your browser), pixels, and other, similar technologies. Visto also obtains data from third parties, including device data, geolocation data and audience attributes data from Device Atlas, NeuStar, Grapeshot and Lotame.

Data Use and Sharing

Personal information you provide Visto is used by Visto for contacting you about services or information requested by you, as well as for direct marketing purposes and may be shared between our offices for this purpose. We also use personal information for our legitimate interest to enhance the services offered on our website via research and analytics about how it is used. We also use personal information, subject to your consent, to tailor advertising delivered to you. We additionally use Activity Information for the purpose of our legitimate interest in operating and improving our website, analyzing demographic and statistical research about website usage, monitoring the website for compliance with our terms of service and the law, and other purposes. We also use Activity Information, subject to your consent, to tailor our marketing and advertising to you through the use of automated-decision making processes about your interests. This process is used to deliver relevant advertising to you and to customize your experience on our website. We may share this information with third parties who provide administrative services on our behalf, such as email fulfillment services, data storage, and web hosting, as well as pursuant to a court order or to law enforcement or government officials, or otherwise to protect the legal rights or legitimate interests of Visto. We may also share information with third parties to deliver advertising to you online and on mobile devices. These third parties are located in the United States. From time to time, Visto may conduct surveys through various online methods. When participating in a survey, we may ask you to provide personal information. The personal information you submit in a survey may be used by Visto for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. If you wish to contact us about surveys conducted by Visto, you can reach us by email at visto@vistohub.com. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy proceeding, or similar event, we reserve the right to include any information we have among the assets transferred to the acquiring company.

Data Retention

Visto stores Personal information you provide to us as long as needed to respond to your inquiries, provide you service, and maintain our relationship with you. We typically store Activity Information for no longer than 180 days.

Choice and Opt-Out

Visto is a member of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) and adheres to their respective self-regulatory codes. The NAI and DAA administer programs that provide consumer awareness and choices regarding web viewing data. As a member of these programs, we provide choice via the DAA and NAI choice tool. Additionally, Visto may partner with other advertising networks and providers to deliver ads on our behalf, or on behalf of others, across the Internet. These third party companies collect information about your visits to our website, and non-affiliated websites and mobile apps over time and across associated browsers and devices in order to provide you with more relevant advertising on other websites and mobile apps. This type of advertising in known as interest-based advertising. If you‘d like to exercise choice with respect to Visto’s or any other DAA participants‘ collection and use of data from your browser in connection with interest-based advertising, please click here www.aboutads.info/choices. You can also exercise choice about participating companies‘ collection and use of data in mobile apps on your device by downloading the DAA‘s AppChoices app to your device by following instructions at http://youradchoices.com/appchoices. Exercising choice through these tools will stop the collection of data from the browser or device where choice was made for interest-based advertising on that browser or device and associated devices, and the use of information collected from associated devices for interest-based advertising on the opted-out browser or device. Note that electing to opt out will not stop advertising from appearing in your browser or mobile device. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or device, or delete cookies from your browser, you may need to renew your opt-out choice.

Manage my choices

Individual Rights

You have the right to request the exercise of the following individual rights where relevant:

  • To access information we maintain about you.
  • To correct information we maintain about you, such as an email address.
  • To request that we erase information we maintain about you.
  • To restrict our processing of information we maintain about you.
  • To object to our processing, or exercise your right to data portability.

If you provided us with information based on consent, such as information used for interest-based advertising, you can withdraw that consent. In order to exercise these rights you can contact us at legal@vistohub.com. We may be unable to facilitate these rights in certain circumstances.

Children

Visto does not knowingly collect personal information from children under the age of 13 through the Website. If you have reason to believe that a child under the age of 13 has provided personal information to Visto, please contact us.

EU-US Privacy Shield

Visto complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or European Economic Area to the United States. To learn more, please view our EU-U.S. Privacy Shield Policy.

Links To Other Websites

We may provide links to third-party sites, which are maintained by third parties. Please be aware that we are not responsible for and cannot control the privacy policies of these other linked sites or their practices. We suggest that you visit those sites directly for information on their privacy, security, data collection and distribution policies because they may differ from Visto’s own position under this Privacy Policy.

Security

We have reasonable security measures in place intended to help protect against the loss, misuse or alteration of personal information we maintain. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.

Changes To Our Privacy Policy

This Privacy Policy is effective as of the date listed at the top of this policy. We may change this Privacy Policy from time to time, and will post prior notice of any such changes on our website.

Data Protection Authorities

You have the right to make a complaint about Visto’s data practices to your local supervisory authority. To do so, you can visit the appropriate authority‘s website.

How To Contact Us

If you wish to contact us about this Privacy Policy you can reach us by email at legal@vistohub.com or by telephone at US +1 646.790.8575. You may reach Visto’s office of data protection at legal@vistohub.com and the below:

Visto Legal Department
72 Madison Avenue, 3rd Floor
New York, NY 10013
United States of America