This privacy policy (“Policy”) describes how Closed Loop Marketing, Inc., (“Closed Loop”) collects, uses and shares personal information of users of the Closed Loop website www.closedloop.com (the “Site”). This Policy also applies to any of our other websites that post this Policy. This Policy does not apply to websites that post different statements.

Closed Loop processes Personal Data as a Processor, as defined in the General Data Protection Regulation (GDPR). Closed Loop uses Consumer Personal Information solely for Business Purposes, as defined under The California Consumer Privacy Act of 2018 (CCPA). This Policy is governed by the GDPR, the CCPA, and other applicable privacy laws.

WHAT WE COLLECT

We get information about you in a range of ways.

Information You Give Us. We collect the following information and other information you directly give us on our Site: name, company name, e-mail address and phone number.

Information We Get from Others. We may get information about you from other sources. We may add this to information we get from this Site. In particular, we use Google account credentials from you so we can access data in your Google Ads™ account, and we may collect other account credentials for similar services in order to access data related to those services.

Information we obtain using these credentials includes: cost, campaigns, ad groups, ads, impressions, clicks, screenshots, destination URLs, cost per conversion, conversion rate, status, destination URLs, conversions, dates, average position, and other information relating to your ad accounts and the performance of websites for which you use the Closed Loop service.

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log information about your use of and actions on our Site.

Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. Cookies help us make our Site and your visit better. We use cookies to see which parts of our Site people use and like and to count visits to our Site.

Security Information. We may also collect certain standard information about your computer for security and identification purposes. This information may include: IP addresses, domain names, access times, browser type and browser version, cookies, and other unique identifying information of machines that have our software downloaded and installed on them. This information is used for the operation of the service, to identify and protect our customers and to control unauthorized use or abuse of our services.

Web Analytics. We continuously improve the Site and utilize different internal and third-party web analytical tools to help us do so. We are interested in how visitors use the Site, what they like and dislike, and where they have problems. These tools may gather data such as what browser a person uses, what operating systems are used, what is downloaded, and what content, products and services are reviewed when visiting or registering for services on our Site. This information is used solely to assist Closed Loop in maintaining a more effective and useful Site. We, or our third-party service providers acting on our behalf, collect and track information including aggregate traffic patterns, domain names, browser types, MIME types and web pages visited before coming to our Site. To increase functionality and enhance your user experience, this information may sometimes be correlated with personal information about individual users.

Links to other sites. The Site may contain links to other websites that are not owned or controlled by Closed Loop. The linked websites may have their own privacy policies which we strongly suggest you review. To the extent such websites are not owned or controlled by Closed Loop, we are not responsible for the websites’ content or privacy practices, or for any use of the websites.

USE OF PERSONAL INFORMATION

We use your personal information in performance of the Closed Loop service, including, without limitation, for account verification, accessing websites and other information necessary to provide the Closed Loop service. We may use your personal information to communicate with you regarding your services and to send you periodic newsletters, offers and usage tips. You may opt out of promotional e-mails at any time, but may still receive communications related to your use of the Closed Loop service and Site, such as service updates and other communications necessary for us to provide services to you.

We may use information we obtain through the Site in other ways for which we provide specific notice at the time of collection.

SHARING OF PERSONAL INFORMATION

We may share personal information as follows:

  • We may share certain personal information we collect about you with our service providers who perform functions on our behalf. Examples include sending postal mail and email, analyzing data, and providing marketing assistance and customer service. These service providers are not authorized by us to use or disclose personal information except as needed to perform their functions or comply with legal requirements, and they may not use it for any other purpose.
  • We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies. By using the Site and the Closed Loop service, you are deemed to give your consent to use the information you provide to perform those services.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of Closed Loop, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with those who need it to do work for us.

We may also share aggregated and/or anonymized data with others for their own uses.

INFORMATION CHOICES AND CHANGES

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about personal information to the address provided below. You may speak with a representative to make a request by calling 916-367-5213. Requests can also be made via email to privacy@closedloop.com.

You can request Closed Loop to disclose the categories of Personal Information, as defined under the CCPA, or Personal Data, as defined under the GDPR, it has collected on you; the categories of sources from which the Personal Information or Personal Data has been collected; the business or commercial purpose for collecting or selling Personal Information or Personal Data; the categories of third parties with whom Closed Loop shares Personal Information or Personal Data; and the specific pieces of Personal Information or Personal Data Closed Loop has collected about you. Responses to all verifiable disclosure requests shall be provided free of charge within forty-five (45) days of when the request was made.

You can request to change contact choices, opt-out of our sharing with others, and update your personal information. You can also request for the deletion of Personal Information or Personal Data you provided to Closed Loop. Closed Loop will promptly comply with the deletion request, unless Closed Loop is exempted from complying with the request under subsection 1798.105(d) of the CCPA. Closed Loop will also direct any service provider to delete your Personal Infomration or Personal Data from their records. Closed Loop does not guarantee the compliance of its service providers with the deletion request. Closed Loop will cooperate, to the extent required by both the GDPR and the CCPA, in any investigation that may result from a service provider’s noncompliance with a deletion request.

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you do not accept cookies, you may not be able to use all portions of the Site or all of the functionalities of Closed Loop and services.

SECURITY OF YOUR PERSONAL INFORMATION. We take steps to help protect personal information. No company can fully prevent security risks, however. Mistakes may happen. Bad actors may defeat even the best safeguards. Closed Loop will cooperate, to the extent required by both the GDPR and the CCPA, in the investigation of security risks and/or breaches.

CONTACT INFORMATION. We welcome your comments or questions about this privacy policy. You may contact us via e-mail at privacy@closedlooop.com, by calling 916-367-5222, or by writing to us at:

Closed Loop Marketing, Inc.
Attn: Closed Loop Privacy Policy
970 Reserve Dr, Suite 206
Roseville, CA 95678

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will change the “last updated” date below.

This privacy policy was last updated on December 13, 2018