PRIVACY POLICY

Updated December 2020.

Alpha Precision Media, Inc. (“Alpha” or “we” or “our”) is committed to protecting your privacy. Alpha helps advertisers connect with consumers by running an advertising buying service leveraging the Amazon Demand Side Platform for digital media and data that allows advertisers to show digital advertisements to individuals who may be interested in their products or services.  

This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share data and the options available to you. If you have any questions, you may contact us. See Contact Us below. For more information on how we receive your information from our advertiser customers and their data practices, please contact the advertiser directly.

We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See Changes to this Privacy Policy below for more information.

California Users: If you are a resident of the State of California, see California Rights for additional information about your rights.

SCOPE OF PRIVACY POLICY

This Privacy Policy applies to your information that we may collect or receive:

  • directly from you on www.apm.inc, www.alphaprecisionmedia.com, our user interfaces and mobile applications (for example, when you fill out your contact information on the “Get Started” page of our site), and directly from you when you send emails to us or when you call us (collectively, the “Alpha Pages”), and
  • through our technology and platform that is used by our advertiser customers and third parties (the “Platform”). Updated and effective as of  March 1, 2020

User Consent: By accessing or using our Alpha Pages or the Platform, you represent that you are at least 18 years old and you consent to our data practices as described in this Privacy Policy. If you do not want information about you to be used in the manner described in this Privacy Policy, please do not use or access the Alpha Pages or Platform.

International Transfers: see How we transfer information internationally below for information on the transfer of your personal information from outside the US to within the US.

Choice and Opting Out: see Choices and Opting Out below for information about opting out of email marketing messages from Alpha, opting out of interest-based advertising by Alpha and third parties via cookies and in mobile applications, opting out of cross-device targeting, and opting out of the use of location data.

User Rights: see User Rights below for information about how to exercise your rights regarding the personal information that Alpha maintains about you.

CHANGES TO THIS PRIVACY POLICY

Alpha may change this Privacy Policy at any time. The most recent version of the Privacy Policy is indicated by the “Updated and effective as of” date at the top of this Privacy Policy. Please review this Privacy Policy regularly to stay updated on changes that may affect you. Your continued use of the Alpha Pages and Platform signifies your continuing consent to be bound by this Privacy Policy. Where required by law, we will obtain your consent or notify you, prior to making these changes.

CONTACT US

If you have any questions about this Privacy Policy or Alpha’s data practices, please email us at privacy@apm.inc or contact us at:
    Alpha Precision Media, Inc.
    Attention: Privacy
    180 Bayview Ave.
    Northport, NY 11768

INFORMATION WE COLLECT AND THE SOURCES OF THE INFORMATION

Information Provided Directly by You. We may collect certain personal information directly from you via our Alpha Pages. For example, when you contact us from the “Get Started” page, we collect the personal information that you provide. Information that you may provide directly to us includes:

  • name
  • email address
  • phone number
  • information you provide when you post comments on ourAlpha Pages, and
  • records and copies of your correspondence when you contact us.

Alpha is not responsible for information that you might provide when commenting on our site.

Every time you enter information into a web form or other data field available on the Alpha Pages or whenever you send us an electronic message, we collect and store that information for our business use. Please do not include any sensitive information in these forms and fields.

Some of the information you provide is optional. However, if you decide not to provide certain information, you may not be able to access the information you had requested to access to, or you may not be able to use part or any of the Alpha Pages or Platform.

Automatically Collected Information.  When you access the Alpha Pages or digital properties that use our Platform, open one of our HTML emails, interact with advertisements served by us, then in those cases we may collect certain information automatically from your browser, mobile device or identifier, IP address, cookie or email.  The technologies we may use for this collection include pixels, web beacons and cookies. See Cookies and Similar Technologies below. This automatically collected information may include the following.

  • cookie identifiers, including our advertiser customers’ unique cookie identifiers and our own cookie identifier,
  • location data derived from IP address (Internet Protocol address) or as supplied by owners of digitial properties (for example, owners or operators of websites and mobile applications that you access may provide your location data),
  • IP address (Internet Protocol address),
  • device information such as mobile device identifier, mobile device type, and operating system,
  • browser information such as browser type and browsing information such as the web pages visited, the site that you visited just before visiting a site, the date and time that you used the site, and the date and time an advertisement was shown to you, and
  • information about your interactions with our emails or advertisements such as clicking on links and date and time viewed.

We may also allow analytics companies to use tracking technologies to collect information automatically about the computers and mobile devices of our users.

Information Collected from our Advertiser Customers. We may collect certain information about you that we receive directly from our advertiser customers. The information collected from our advertiser customers includes the following:

  • advertiser customer identifiers assigned to individuals,
  • information about you (e.g., age or gender) or inferences about your interests that an advertiser customer believes will help it to make the ads served to you more relevant,
  • your activities on various digital properties, including the websites or applications, time spent on websites, pages viewed, dates and times of visits, search keywords, and click data,
  • your interaction with our advertiser customers’ ads,ads served, ads viewed, and ads clicked on,
  • IP address,
  • location data,
  • advertiser customer cookie identifier,
  • operating system type and version of your device,
  • information about your browser including browser type, version, and language, and
  • information about your device including device type and device identifier.

Information from Other Sources. We may also receive data from other sources.

If we combine or associate non-personal information with personal information, we will treat the combined information as personal information in accordance with this privacy policy.

HOW WE USE INFORMATION

Providing and Improving the Alpha Pages and Platform.  We use your information to provide and improve the Alpha Pages and the Platform, including responding to your inquiries, serving advertisements, providing technology that allows our advertiser customers to manage advertising campaigns, facilitating navigation on the Alpha Pages and Platform, ensuring our technologies are functioning property, personalizing the user experience while using our Alpha Pages and Platform, analyzing advertising and website performance and campaigns, personalizing communications with you, and developing new services.

Personalizing Ads. We use information (for example, previous websites visited and location) to allow our advertiser customers to deliver advertisements that they believe may be of interest to you.  Also, some service providers will target users of the Alpha Pages when they visit other websites and mobile applications.

Marketing the Alpha Pages and Platform. Where permitted by applicable law, we may use your email address or other personal contact information to send you marketing messages relating to the Alpha Pages or Platform, which you can opt-out of.  We also use your information to monitor the effectiveness of these marketing campaigns.

Detecting Fraud.  We use information about you to detect suspicious patterns which may represent fraud. We may also use the information to identify invalid advertising impressions and queries.

Exploring a Business Transaction. We may use the information as part of exploring a potential merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.

Legal and Other Uses. We may use your information if we believe it is necessary:(a) to prevent or stop activity that we think is, or is at risk of being, illegal or actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Alpha Pages and Platform; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from government authorities and private parties; (g) to enforce our terms; and (h) to allow us to pursue available remedies or limit potential damages.

HOW WE SHARE INFORMATION

We may share your personal information with:

  • Our affiliates.  We may disclose your information to our affiliates (for example, subsidiaries) for the purposes described in this Privacy Policy.
  • Our service providers. We may disclose your information with our service providers who perform functions required for the operation of our business.  Examples include, to provide data storage and processing services, hosting services, campaign management, email management, engineering services, marketing services, technical support, and fraud detection and prevention.  We provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by us.
  • A third party involving a business transaction. We may share your information with a third party as part of a merger, acquisition, debt financing, or sale of our assets, as well as in the event of an insolvency, bankruptcy or receivership.
  • The Public, Voluntarily by You.  Individuals may choose to share information on message boards, chat, profile pages and blogs and other services that allow visitors to post information and materials. Please note that any information posted or disclosed through these services and forums will become public information, and may be available to users of the Alpha Pages and to the general public.  We urge you to be very careful when deciding to disclose your personal information, or any other information, on the Alpha Pages.
  • Legal and Other Disclosures. We may also disclose your information if we believe it is necessary: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal or actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Alpha Pages and Platform; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from government authorities and private parties; (g) to enforce our terms; and (h) to allow us to pursue available remedies or limit potential damages.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and other similar technologies (such as tags, pixels, and mobile device IDs) to collect information automatically from users’ devices.  We use these technologies to help us operate the Alpha Pages, including authenticating users and identifying which pages are viewed more than others and to help us improve the Alpha Pages.  We may also use these technologies on our Platform to ensure ads are displayed properly and to perform analytics and showing ads based on your interests.

We also use cookies to store your choice to opt out of interest-based advertising,
Cookies: A cookie is a small datafile that is stored on your computer’s or mobile device's memory.  Cookies are used to collect information about how you interact with websites or advertisements.Cookies also save information so that websites can remember preferences you had or recognize (e.g., if you save your log in information, a cookie is set to remember you).

Tags, pixels and web beacons: Tags, pixels and web beacons are electronic images that are placed on a web page or in a mobile application and may be associated with cookies on your device. Some pixels are used to drop cookies. Pixels can help us count users who have visited our Alpha Pages, determine the effectiveness of marketing campaigns, and analyze usage patterns (e.g., how people interact with websites or advertisements). We create and use a synchronization system to check the quality of information that we have collected with information that our advertiser customer collected independently, and to help our advertiser customers provide you with targeted advertisements.

Mobile device identifiers: Mobile device identifiers or mobile device IDs are unique identifiers which can be used to identify a mobile device. We may use these device identifiers to track your use of mobile applications and to determine if a piece of ad inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing mobile device IDs back to our advertiser customers helps us and our advertiser customers to improve the quality of advertising and its efficiency.

Third party cookies and technologies: The collection of information through cookies or similar technologies by third parties (including social media platforms) is governed by such third parties’ own privacy policies and principles, which Alpha does not control. Social media platforms may store cookies and similar technologies on your device if you use the social media platform’s sharing button or widget on our Alpha Pages. Third parties may also use cookies or similar technologies on visitors of our Alpha Pages to serve interest-based advertisements to such visitors based on their privacy policies, when those visitors visit other websites and mobile applications.

Do not track headers: At this time, we do not honour “Do Not Track” headers and similar mechanisms.To opt out of the use of these technologies above, see “Choices and Opting Out” below.  For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.  To read about your choices with regard to Alpha’s and third parties’ uses of cookies, please see “Choices and Opting Out.”

CHOICES AND OPTING OUT

Opting Out of Marketing from Alpha

You may opt out from receiving email marketing communications from us (or opt in, if required by applicable law). If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by contacting us at privacy@apm.inc or by clicking on the opt-out link within the email message that you receive from us.

Please note that if you do opt out of receiving marketing-related emails from us, we may still be required to send you administrative messages from time to time.

Deleting cookies

You may delete or disable cookies by modifying the settings in your browser. Please note the following:

  • If you delete or disable cookies some features of the Alpha Pages may not work.
  • If you delete cookies after previously opting out of Alpha’s interest based advertising cookie (see below), you will need to renew your opt-out choice. By deleting all cookies, you are deleting your opt out cookies.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.  

Opting Out of Interest-Based Advertising via Cookies

Some of our advertising customers have their own opt-out mechanisms that are linked from their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.

Please note the following:

  • When you opt out of interest based advertising from Alpha, an opt out cookie will be stored in the browser where you exercised the opt out. Other companies may use opt out cookies as well.
  • The opt out only applies to the applicable browser in which you set it.
  • If you block cookies, you will not be able to use our opt out tool because our opt out is cookie-based.
  • If you delete cookies, then you will need to opt out again because our opt out is cookie-based.
  • After opting out of interest-based advertising from Alpha or any third party, you will still receive advertisements, but such advertisements will not be interest-based ads targeted by Alpha and such third party.

If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third party websites, online services, devices, and applications for interest-based advertising purposes.

Please visit www.allaboutcookies.org. To learn more about cookies and how to see what cookies are set on your device and how to manage and delete cookies.

Opting Out of Interest-Based Advertising in Mobile Applications

To opt out of Alpha’s interest-based advertising that takes place through mobile applications, please see the instructions below on utilizing your mobile device operating system’s opt-out settings.

For iPhone/iOS users: For instructions on how to “Limit Ad Tracking” on the iOS, please visit this link or see the instructions below:

  1. Go to “Settings” > “Privacy” > “Advertising.”
  2. Turn on “Limit Ad Tracking.”

For Android users: For instructions on how to opt out of interest-based ads in the Android OS, please visit this link or see the instructions below:

  1. Open Google settings on your device (may be an app called Google Settings or an entry in your phone’s Settings menu, depending on your device)
  2. Tap “Ads”
  3. Switch on “Opt out of interest-based ads” or “Opt out of Ads Personalization.”

Opting Out of Cross-Device Targeting

We may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. For example, if you use a shopping-related mobile application on your smartphone, later when you go to another application on your table, you may receive a shopping-related ad. To opt out of these practices, please follow the instructions above for “Opting Out of Interest-Based Advertising from Cookies” and “Opting Out of Interest-Based Advertising in Mobile Applications.

”You will need to opt out separately on:

  1. each of your browsers and
  2. each of your mobile devices.

This will ensure that information collected on a particular browser or device is not used on another browser or device.

Opting Out of Use of Location

You can access your mobile device settings to limit the collection of location from your mobile device through mobile applications. Note: if you limit location settings, we (and third parties) may still infer data about your location based on your IP address.

Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).

iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.

USER RIGHTS

If you would like to review, correct, access, update, or delete the personal information that Alpha maintains about you, you may contact us at privacy@apm.inc or at our address below.  Depending on where you reside, you may have additional rights with respect to your data. If you are a California resident, see your additional rights under California Rights below.

Alpha Precision Media, Inc.
Attention: Privacy
180 Bayview Ave, Northport, NY 11768.

To opt out of receiving marketing communications from us, please see “Choices and Opting Out.”

To opt out of Alpha’s cookies, please see “Choices and Opting Out.”

To opt out of interest-based advertising by Alpha and third parties, please see “Choices and Opting Out.”

To opt out of interest-based advertising in mobile applications, please see “Choices and Opting Out.”

To opt out of cross-device targeting, please see “Choices and Opting Out.”

To opt out of the use of location, please see “Choices and Opting Out.”

CALIFORNIA RIGHTS

This section applies to California residents whose personal information we collect. We adopted these additional rights in order to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this section.

This section does not currently apply to workforce-related personal information collected from our California-based employees, job applicants, contractors, owners, directors and officers and personal information reflecting a written or verbal business-to-business communication.

Certain other personal information is also currently exempt from these rights under California law. For example, the following types of information are not considered personal information under or are exempt from the CCPA: publicly available information from government records, de-identified or aggregated consumer information, certain health or medical information, and certain financial information.

Access to Specific Information and Data Portability. If we received your information from an advertiser customer, you will need to make the request directly with the advertiser customer unless the advertiser customer has authorized us to respond directly to you. If we are permitted to respond to your request, once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we shared that personal information.
  • The specific pieces of personal information we collected about you (which will allow you to exercise your data portability right).

Deletion Request. If we received your information from an advertiser customer, you will need to make the request directly with the advertiser customer. If we are permitted to respond to your request, once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Process or maintain personal information on behalf of an advertiser customer that provided or directed us to collect the information.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Rights of Access, Data Portability, and Deletion. If we received your information from an advertiser customer or on behalf of an advertiser customer, you will need to make a request directly with the advertiser customer. If we are permitted to respond to your request, to exercise your rights above, please submit a verifiable consumer request to us by either:

  • Emailing us at privacy@apm.inc and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).
  • Sending us your request to our physical address:

Alpha Precision Media, Inc.
Attention: Privacy
180 Bayview Ave.
Northport, NY 11768

Only you, or someone legally authorized to act for you, may make a verifiable consumer request about your personal information. You may also make a verifiable consumer request for your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand and respond to it.

We cannot respond to your requestor provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We may require you to make your request through your account if you have an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Format of Response and Timing. If your personal information was collected by us on behalf of our advertiser customer, we will inform you that you must contact the advertiser customer directly, unless the advertiser customer has authorized us to respond directly to your request.

If we are permitted to respond to your request on behalf of an advertiser customer, we will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period.

We will make efforts to respond to your request in the same manner that you submitted your request. For example, if you emailed us, we will respond to you via email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format (such as a plain text file) to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

HOW WE TRANSFER INFORMATION INTERNATIONALLY

The information we collect, is transferred to and maintained on servers or databases located in the United States, where the privacy laws may not be as protective as those in your location. We process and store information in any country where we have facilities and/or employees, or in countries where we engage service providers.

You consent to the transfer of your personal information to, and the storage and processing of your personal information in the United States and any country where we have facilities and/or employees and in countries where we engage service providers, which may have different data protection rules than those of your country of residence.

THIRD PARTIES

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties including our advertiser customers and any third parties operating any site or service to which our Alpha Pages link (except as required by applicable law). The inclusion of a link on the Alpha Pages does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies. You are responsible for knowing and understanding their policies and terms.

SECURITY

The security of your information is important to us.  We have implemented reasonable security measures to maintain the safety of your personal information.

RETENTION OF INFORMATION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law, or an individual requests deletion in accordance with applicable law. See “User Rights.”

CHILDREN

Our Alpha Pages and Platform are not intended for, nor directed to, children. We do not collect information from the Alpha Pages or Platform from any person we actually know is an individual under the age of 18.  Anyone under the age of 18 is not permitted to use the Alpha Pages or Platform and must not submit any personal information to us.If we become aware that a child under the age of 18 has provided us with personal information, we will take steps to remove such data. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@apm.inc.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose to us, any sensitive information (for example, social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Alpha Pages or Platform or otherwise to us, except where such information is legally required.