Privacy Policy
Effective Date: July 18, 2012
Thank you for visiting the HasOffers™ website located at www.hasoffers.com (the “Site”) – property of HasOffers, Inc., a Washington State corporation (“HasOffers,” “we” or “us”). HasOffers is committed to protecting the privacy of our visitors’ personally identifiable information. We provide this privacy policy (“Privacy Policy”) in order to explain our online information practices and the choices you can make about the way your information is used by us. You must agree to this Privacy Policy, in its entirety, including our use of cookies in order to: a) access or use our Site; and/or (b) subscribe to any of the HasOffers affiliate network management products and/or services (the “Services”) offered on the Site (each, a “Subscription”). Your acceptance of both this Privacy Policy and our use of cookies on the Site shall be deemed a blanket acceptance of such Privacy Policy and cookie usage for all future attempts to access the Site and/or any Subscription of the Services. If you do not agree to this Privacy Policy in its entirety, you are not authorized to become a subscriber (“Subscriber”) to the Services and/or use the Site in any manner or form whatsoever.
Privacy Policies Used in Connection with Your Subscription.
Potential affiliates that sign up for the affiliate program that you establish by and through the Services do so from links on your website or via a Uniform Resource Locator (“URL”) supplied to you via the Services (collectively, “Subscription Website”). Such affiliates’ information is stored on the password-protected portal established by and through the Services. HasOffers will not access the affiliate information stored on your password-protected portal unless you specifically request that we do so. You are solely responsible for choosing, and uploading to applicable areas of your Subscription Website, a privacy policy to govern your affiliate program, in which conspicuous written notice is given to internet users who access your Subscription Website (“Subscription Users”) that cookies may be used to collect anonymous traffic data, and for which you receive consent prior to placing cookies on the internet device of any such Subscription User. HasOffers is in no way responsible for the collection, storage, use and/or distribution of any data that is submitted by and through your Subscription Website.
Personally Identifiable Information.
We collect personally identifiable information on the Site when you attempt to become a Subscriber or otherwise choose to provide personally identifiable information to us. Personally identifiable information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: business entity name and/or your title with the applicable business entity, as well as your personal and/or business entity related e-mail address, mailing address, daytime and/or cellular telephone numbers, fax number, credit card and/or any other information requested on the applicable Subscriber registration form. For purposes of this Privacy Policy, your credit card shall be considered “Sensitive Information.”
Non-Personally Identifiable Information.
We may collect certain non-personally identifiable information about you when you visit many of the Site’s pages, such as the type of browser you are using (e.g., Netscape, Internet Explorer), the type of operating system you are using, (e.g., Windows ’98 or Mac OS) and the domain name of your Internet service provider (e.g., America Online, Earthlink). We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.
Cookies and Web Beacons.
To enhance your experience with the Site, we use “cookies.” You cannot use this site or the Services without agreeing to accept the cookies that we use with the Site. For more specific information on the cookies we use, please see Exhibit A, below. Cookies are small packets of data stored on your computer. Cookies are used by your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. We use cookies to understand Site usage and to improve the content and offerings on the Site. You may set your browser to warn you that cookies are in use, or to block the use of cookies. Most browsers are set to accept cookies. If your browser is not set to accept cookies, certain uses of the Site may require you to go to your browser user preferences to enable cookies. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser. To find out more about cookies, please visit www.cookiecentral.com.
We may additionally collect information using Web beacons, which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs. Web beacons are electronic images that may be used on the Site, in our Services, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon.
HasOffers also utilizes a third party retargeting campaign that uses cookies to keep track of your interaction with HasOffers. You may opt-out of such retargeting by clicking here https://www.adroll.com/about/privacy and following the opt-out procedure.
Use of Information.
We use your personally identifiable information: (a) to send you information regarding HasOffers and your Subscription to the Services; (b) to track your compliance with the HasOffers Services Agreement (“Services Agreement”); and/or (c) for validation, suppression, content improvement and feedback purposes. You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Services and request for information regarding additional HasOffers products and/or services.
Information Sharing.
As a general rule, and other than in connection with the limited exceptions set forth below, HasOffers will not sell, share or rent your personally identifiable information to or with others. Notwithstanding the foregoing, HasOffers may, from time to time, provide such information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services in connection with your Subscription to the Services such as billing and delivery. Any third-party vendor so used has agreed to protect the confidentiality of information provided by HasOffers.
Further, HasOffers reserves the right to share your personally identifiable information: (a) where required by law, or requested by a court of competent jurisdiction; (b) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of HasOffers’ business, assets or stock; (c) where you are in violation of this Privacy Policy, and/or Services Agreement; (d) in the case of a dispute; or (e) where HasOffers determines, in its sole discretion, that such disclosure is necessary to protect the rights of HasOffers and/or a third party, or necessary to protect HasOffers from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.
International Transfer of Data.
In the process of providing the Services to you, we may transfer information that we collect about you and your Subscription Users and any end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your End Users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your Subscription Users and any end users, including personal information, as described in this Privacy Policy.
The HasOffers Blog.
The HasOffers blog, located at http://www.hasoffers.com/blog/ is an optional resource for information and opinions related to the performance marketing industry. When you subscribe to the HasOffers blog, we will require you to provide us with your name and email address. By subscribing to the HasOffers blog you are agreeing to accept emails that include a compilation of blog posts and information about the HasOffers product line. You may opt-out of receiving such emails at any time by clicking on the link at the bottom of the emails or by emailing optout@hasoffers.com. The HasOffers blog is primarily designed to help you obtain and share information and opinions related to the performance marketing industry. Any comment that you post will be made public, along with your user name or email if you log-in through one of the provided social networking sites (for information on how these sites use cookies and your personal information please see their corresponding privacy policies); however you may choose to post anonymously. When you leave a comment you agree to the disclosure, transfer, manipulation or deletion of your comment or any part thereof by HasOffers.
Data Retention.
Subject to any mandatory obligations to delete data, we may choose to retain information in our server logs, our databases and our records indefinitely.
Third Party Links.
The Site may contain links to third-party websites (“Third Party Websites”). Please be aware that HasOffers is not responsible for the privacy practices of Third Party Websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Site.
Minors.
We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. HasOffers will never knowingly collect any personal information about individuals under eighteen (18) years of age. If HasOffers obtains actual knowledge that it has collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from its database.
Your Employees.
Your acceptance of the terms of this Privacy Policy, in their entirety, shall inure to your employees, if any. You agree that any employee who accesses your Account, or who visits the Site under the scope of such employee’s employment with you (and any third party to whom you give rightful access to your Account or Site) agrees to the terms of this Privacy Policy, including, without limitation, our use of cookies and/or web beacons.
Security.
We endeavor to safeguard and protect our users’ information. When users submit personally identifiable information at the Site, their personally identifiable information is protected both online and offline. When our registration process asks users to submit Sensitive Information (such as bank account information), and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we protect all other user information online and offline. The servers that we store personally identifiable information in are kept in a secure physical environment. We have security measures in place to protect the loss, misuse and alteration of personally identifiable information under our control.
Please be advised that, although we take every reasonable precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your information will be absolutely secure. Any transmission of data at or through our Site is at your own risk. However, access to your personally identifiable information is strictly limited, and not accessible to the public. Only employees, and third party agents, that need the information to perform a specific job are granted access to personally identifiable information. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
You acknowledge that you provide your personally identifiable information to HasOffers with knowledgeable consent and at your own risk.
Deleting and Updating Your Information.
If you would like to delete or update the personally identifiable information that we have collected from you, simply send your request via certified mail to: HasOffers, Inc., 2220 Western Avenue, Seattle, WA 98121. You may also send your request via e-mail to: support@hasoffers.com.
We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
Opting Out of Receiving E-mail.
You may at any time choose to stop receiving emails containing general information regarding HasOffers and/or HasOffers by following the instructions at the end of each such email or by contacting us at optout@hasoffers.com. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Subscription to the Services, as well as to respond to any inquiry or request made by you.
Notification of Changes.
HasOffers reserves the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the Site explaining that we are changing our Privacy Policy. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.
Safe Harbor.
Just as with all of its visitors from every region of the globe, HasOffers recognizes the importance of protecting the privacy of its visitors from the European Economic Area (EEA) and Switzerland. Visitors to HasOffers’ websites from the EEA and Switzerland can learn about HasOffers’ Safe Harbor Privacy Policy by clicking here. With respect to Personal Data that is transferred from the EEA or Switzerland to the United States, any conflict arising between the Safe Harbor Privacy Policy and this Privacy Policy, the Safe Harbor Privacy Policy shall control, but only to the extent necessary to resolve the conflict.
Contact Us.
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at: privacy@hasoffers.com.
Exhibit A
More about cookies on HasOffers.com
Using hasoffers.com requires the use of cookies. If you have do not want to accept the cookies for hasoffers.com or from any of our third parties, you won’t be able to use our service.
We use a cookie to remember your cookie preferences this has a couple of consequences
- If you delete all your cookies you will have to update your preferences with us again.
- If you use a different device, computer profile or browser you will have to tell us your preferences again.
The cookies used on hasoffers.com are based on the International Chamber of Commerce guide for cookie categories:
For more information about cookies see the further reading link below.
Strictly Necessary
‘Strictly Necessary’ cookies let you move around the website and login to your secure account. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet.
We use these Strictly Necessary cookies to…
- Identify you as being logged in to hasoffers.com
- Remember things like information you’ve entered on forms when you navigate to different pages in a single web browser session
- Help you use specific features like testing tracking links
- Make sure you connect to the right service on our website when we make any changes to the way the website works
Cookies we have defined as ‘Strictly Necessary’ cookies will NOT be used to…
- Gather information that could be used to advertise products or services to you
- Remember your preferences or username beyond your current visit
Accepting these cookies is a condition of using the website, so if you prevent these cookies we can’t guarantee your security or predict how our website will perform during your visit.
Here is a list of the cookies we have defined as ‘strictly necessary’.
hasoffers.com cookies
- PHPSESSID
Cookies provided by 3rd parties
| Cookie | Host |
|---|---|
Performance
‘Performance’ cookies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. These cookies don’t collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our website works, understand what interests our users and measure how effective our advertising is.
We use performance cookies to…
- Provide statistics on how our website is used
- See how effective our adverts are (we don’t use this information to target adverts to you when you visit other websites)
- Provide feedback to partners that one of our visitors also visited their website. This can include details of any products bought. This lets our partners improve their website, but we don’t allow our partners to reuse this information for further advertising
- Help us improve the website by measuring any errors that occur
- Test different designs of our website
Cookies we have defined as ‘Performance’ cookies will NOT be used to…
- Remember your preferences or username beyond your current visit
In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above.
Using our site indicates that you accept the use of ‘Performance’ cookies.
Accepting these cookies is a condition of using the website, so if you prevent them we cannot guarantee how our site will perform for you.
Here is a list of the cookies we have defined as ‘Performance’.
hasoffers.com cookies
- aff_conversions
- __utma
- __utmb
- __utmc
- __utmz
- _pmy_visit
- _pmy_visitor
- is_returning
- chartbeat2
Cookies provided by 3rd parties
| Cookie | Host |
|---|---|
Functionality
‘Functionality’ cookies are used to provide services or to remember settings to improve your visit.
We use ‘Functionality’ cookies to…
- Remember settings you’ve applied such as layout, text size, preferences and colours
- Remember if we’ve already asked you if you want to fill in a survey
- Provide proactive live chat sessions to offer you support or submit a trouble ticket
- Show you when you’re logged in to the website
- Share information with partners to provide a service on our website. The information shared is only to be used to provide the service, product or function and not for any other purpose
Cookies defined as ‘Functionality’ will not be used to…
- Target you with adverts on other websites
Some of these cookies are managed for us by third parties – where this is the case we don’t allow the third party to use the cookies for any purpose other than those listed above.
You can control whether or not these cookies are used, but preventing them may mean we can’t offer you some services, and will reduce the support we can offer you. It’s also possible that preventing these cookie stops us remembering that you didn’t want a specific service.
Here is a list of the cookies we have defined as ‘Functionality’.
hasoffers.com cookies
- app_user
- swidth
Cookies provided by 3rd parties
| Cookie | Host |
|---|---|
| edition | .hasoffers.com |
| network_id | .hasoffers.com |
| networkname | .hasoffers.com |
| networkurl | .hasoffers.com |
| __lc.serverchat1c | .livechatinc.com |
| redirect | .adroll.com |
Further reading
Information about cookies
Useful information about cookies can be found at:
http://www.allaboutcookies.org
Internet Advertising Bureau
A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at:
http://www.youronlinechoices.eu
International Chamber of Commerce United Kingdom
Information on the ICC (UK) UK cookie guide can be found on the ICC website section:
http://www.international-chamber.co.uk/our-expertise/digitaleconomy