Privacy Policy

1. ClickPattern provides solutions for performance marketers. ClickPattern is the leading ad tracking software, used by the world's top advertisers and agencies to manage their online advertising operations. Clients use ClickPattern to assess the effectiveness of their digital marketing campaigns by measuring user clicks and conversions.

This Privacy Policy is provided to help you understand how ClickPattern processes end user data on behalf of advertising networks who use the ClickPattern platform. It does not state the use practices or policies of our clients, of the websites or apps on which ads are shown, or of other parties.

We hold in high esteem the privacy of every ClickPattern's user/clients. We want you to understand that we apply our long term commitment to protecting privacy to the online and internet activities. This Privacy Policy contains the details about the information ClickPattern will collect and how we will make use of the said information.

ClickPattern and our clients care about how end-user data is collected, used, and shared. We are a "data processor" that collects and analyzes end-user data at the specific request of our clients, the "data controllers". This Privacy Policy relates solely to our ClickPattern product. For information on ClickPattern's approach to and preparation for GDPR, please refer here, which is applicable to the users residing in the European Union.

Further, you agree and consent to the fact that ClickPattern may collect, use and disclose your Personal Information in accordance with this Policy. If you do not agree with these terms, you are requested not to provide any personal information to us.

1. ClickPattern just being an Intermediary, our clients determine the data that they provide to and collect through ClickPattern. Clients' use, collection, exportation, or any other use of end-user data, including the use of ClickPattern products and services, is governed by their own privacy policies and applicable laws, rules, or regulations.

2. Client uses ClickPattern to process information from end-users, with an aim of:

• measuring the performance of ad campaigns
• creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region)
• determining when Users respond to ads
• ad serving – ClickPattern uses data that does not personally identify users to target advertising for Clients. End users can be targeted by device type (OS, Make, Model) and imprecise geographic location (state and region).

1. Types of information:

At the direction of our clients, who act as data controllers, ClickPattern collects the following types of information from Users to help clients optimize and measure their advertising network, affiliate and publisher relationships:

• Ad Identifiers
• IP address
• Cookies
• Pixel Tags
• Imprecise Geographic Location Data derived from IP address and/or wifi networks

ClickPattern also collects this information from employees of Clients who access information using their ClickPattern accounts to maintain up-to-date contact information.

Information at Sign Up

At the time of signing up with ClickPattern, we collect contact details – including location, email address, phone, company name, skype ID and website URL. Clients will also need to provide a username and password to set up a ClickPattern account. Please note that ClickPattern treats all Client contact details as confidential business information that will only be used to service Client accounts and respond to Client inquiries in accordance with a contractual agreement or applicable agreement by and between the parties.

Sensitive Information:

ClickPattern collects and treats the sensitive information in terms of the Information Technology Act, 2000 read with the rules thereunder. The disclosures as to sensitive information which may reside with ClickPattern is as follows:

Login Password: The registration requires you to create a password for accessing of ClickPattern services, which is confidential and sensitive information, collected and retained within ClickPattern database. But the said sensitive information is just used by you as a ClickPattern user for gaining access to the services and is not used or accessed by ClickPattern or its affiliates/partners in any way.

Financial Information: The Bank Details may be visible on the cheques couriered to us for payment of any services, but the complete bank account details are never noted down or processed for any reasons whatsoever, with us. Though we recommend direct deposit of payments in our Bank Account either electronic transfer or by the drop of a cheque.

Customer's personal data – ClickPattern do not track or store any customer's personal data without the consent from the client. The data is not passed along to any third-party tool and is stored as part of our databases with all necessary safety measures

In case of payment made by a secured Payment Gateway at ClickPattern, the information is processed at the Payment Gateway, who are PCI Compliant and do not retain the sensitive information for the period more than required. The said online payments are additionally subject to an independent agreement with the payment gateway provider.

Sharing of Information:

ClickPattern uses the personal information (other than the sensitive information) for fulfilling your need and requests for products and services, improve user experience, sending transactional emails or notification you have opted for, for displaying relevant advertisement according to your location, products/services rendered, etc. ClickPattern do not rent, sell, or share personal information (other than the sensitive information) about you with any third parties, except when we have specifically obtained your consent at the time of collection of the information online at ClickPattern or otherwise offline, and/or to provide products or services you've requested, or under the following circumstances:

• We provide the information, other than sensitive information, to trusted partners who work on our behalf of or with us under confidentiality agreements for the purpose of creating / modifying / maintaining the site. However, these companies do not have any independent right to share/use this information for any other purpose, except for that specifically authorised by us.
• The Credit Card Information is collected by the Payment Gateway for processing of the payment and deleted soon thereafter, as declared above. Otherwise, no outside agency has been authorized for the use of any sensitive information for now;
• ClickPattern's administrator may be required to login to the admin panel for troubleshooting, as a result, can get access to the personal data, but which purely can only be for administration and troubleshooting purposes.
• ClickPattern believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of User Agreement, or as otherwise required by law;
• ClickPattern responds to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
• ClickPattern we may transfer such data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. In this event, we will notify you before information about you are transferred and becomes subject to different privacy policy;
• ClickPattern may disclose end-user data in the event we reasonably suspect fraudulent, malicious, or unlawful activity, or invalid traffic, or believe that we are legally required to do so.
• ClickPattern may also share anonymous aggregated data derived from the ClickPattern platform, including, for example, statistics about ClickPattern platform activity.

ClickPattern never uses or share the personally identifiable information provided to us online, in ways or for reasons unrelated to the ones described above.

Third-Party Sources:

Clients can also choose to view and measure information provided by other third-party sources in the ClickPattern platform. Those sources may include Advertisers, other Networks and analytics partners.

Ownership of Data:

Clients own the data that they provide to and collect through the ClickPattern platform. When clients remove or export their data from the ClickPattern platform, their use of data is governed by their own privacy policies and applicable laws, rules, or regulations. ClickPattern serves as a data processor, acting at the direction of our data controller clients. Specific fields that likely contain personal data, such as IP address or device ID, maybe obfuscated or blanked, respectively, by the ClickPattern client.

Our app shares the device information along with advertising id on installation to first party "ClickPattern" for analytics and advertisting purposes to understand how users interact with our app and to measure ad performance.

Client-side Tracking:

Clients use ClickPattern for pixel or server postback tracking to collect information about Users. Pixel tracking (also called "cookie-based tracking" and "client-side tracking") methods store a ClickPattern session identifier in a user's browser cookie on click. In postback tracking (also called "server-side tracking"), ClickPattern directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to ClickPattern for validation. ClickPattern also supports server-to-server measurement for some clients. With any of the mentioned methods, when an end-user click on an advertisement, goes to a specific web page or mobile app action that a Client chooses to monitor, ClickPattern collects information from the User's computer or device, including but not limited to IP and Ad Identifiers.

Cookies:

User can disable cookies in most internet browsers. Disabling cookies will not, however, stop receipt of all advertisements. If an end-user would like to opt-out of a particular ad network, publisher, or advertiser's ads, they will need to contact those companies directly to inquire whether they have an opt-out option. End users can also disable the collection of Ad Identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the Ad Identifier altogether using their smartphone's privacy settings. End users should also note that ClickPattern collects information on behalf of its clients. To opt-out, please see optoutmobile.com or contact the data controller directly. We will actively work with our clients to fulfil such requests as reasonable and required by law.

Tracking Technologies:

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you with advertising based on your browsing activities and interests. You may opt-out by visiting the website of that specific partner like Facebook, Google, LinkedIn, Twitter and Quora.

Adherence to GDPR Policy:

ClickPattern serves as a data processor under the GDPR, and adheres to the principles and rules of the GDPR. Specifically, ClickPattern implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.

Communication:

ClickPattern reserve the right to send you certain communications relating to our services or sponsored advertisements, administrative messages and the Newsletter, that are considered part of your registered account, with an option for you to stop receiving them. We shall also send you emails which shall contain information about our existing or new services or features.

Security:

ClickPattern uses commercially reasonable efforts including a variety of security technologies and procedures to secure client and end-user data from unauthorized access, use or disclosure. Personal information, especially the sensitive information about users that is maintained on ClickPattern systems and is protected using industry-standard security measures. We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. You should be aware that ClickPattern has no control over the security of other sites on the Internet you might visit, interact with, or from which you buy products or services. You should keep your user name, password or other access information safe and confidential to protect against unauthorized access to your account information and services. And you must adopt passwords that others may not guess easily.

Retention of Information:

ClickPattern holding sensitive/ personal data or information of providers of information, shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under the User Agreement or any other law for the time being in force or unless ordered to the contrary by any order of court of law. The information collected shall be used for the purpose for which it has been collected.

Deletion of Information:

You may also request that ClickPattern may delete your Personal Information from system and records. Additionally, you may delete your account anytime at your own free will. However, due to technical constraints and the fact that we back up our systems at regular intervals. Personal Information may continue to reside in our systems after deletion for some limited time.

Location:

The information is collected and retained by ClickPattern on its server located in the USA.

Changes:

ClickPattern may find it necessary to update this Privacy Policy from time to time. Please check this Privacy Policy, as any changes will be posted on this site.

California Resident Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), gives you specific rights regarding your personal information. This section describes those rights and how to exercise them.

Categories of personal information we collect

In the preceding 12 months, ClickPattern may have collected the following categories of personal information, consistent with the descriptions earlier in this Privacy Policy:

• Identifiers (e.g. email address, account username, IP address, advertising/device identifiers)
• Commercial information (e.g. subscription plan, billing records — payment card data is processed by our payment processor and not retained by ClickPattern)
• Internet or other electronic network activity information (e.g. clicks, page interactions, referring URLs, device and browser type)
• Geolocation data (imprecise, derived from IP address)
• Professional or employment information (e.g. company name, role) provided at sign-up
• Inferences drawn from the above to measure campaign performance on behalf of our clients

Your rights

• Right to know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
• Right to delete: You may request that we delete personal information we have collected from you, subject to certain exceptions (for example, to complete a transaction, detect security incidents, or comply with a legal obligation).
• Right to correct: You may request that we correct inaccurate personal information that we maintain about you.
• Right to opt-out of sale or sharing: You may request that we not "sell" or "share" your personal information as those terms are defined under the CCPA/CPRA.
• Right to limit use of sensitive personal information: To the extent we process sensitive personal information, you may request that we limit its use to that necessary to provide the Services.
• Right to non-discrimination: We will not discriminate against you for exercising any of these rights.

"Sale" and "sharing" of personal information

ClickPattern does not sell personal information, and does not share personal information for cross-context behavioural advertising as those terms are defined under the CCPA/CPRA. We act as a service provider to our clients (the data controllers) and only process end-user data at their direction to provide the Services.

How to exercise your rights

To submit a verifiable consumer request, or to ask a question about your California privacy rights, please email privacy@clickpattern.com. We may need to verify your identity before fulfilling your request. You may also designate an authorised agent to act on your behalf, subject to verification.

If you are an end user of a ClickPattern client's campaign, your request may be routed to that client as the data controller, and we will assist them in fulfilling it.

Google User Data Policy Compliance

This disclosure informs you that ClickPattern complies with the Google API Services User Data Policy, including the Limited Use requirements. This means that we only access and use your Google account information for the core functionalities of ClickPattern. You can learn more about Google's User Data Policy here.

Questions About This Privacy Policy?

If you have an unresolved privacy or data use concern that a ClickPattern client or ClickPattern has not addressed satisfactorily, please contact support@clickpattern.com.

Contact Information

If you have any questions regarding this Privacy Policy or would like more information on our privacy practices, please contact us at support@clickpattern.com or by mail at: