Privacy Policy

Last modified: May 22, 2023

INTRODUCTION

SQAD, LLC and its affiliated companies (“SQAD”, “We”, “Us”, or “Our”) provides a dynamic application and data set for advertisers, agencies and brands that empowers their research, review, planning, management and reporting across all media strategies, including network, local and cable television, radio, out-of-home and internet channels.

This Privacy Policy applies to individuals (“you” and “your”) who: (i) may be visitors of the SQAD websites, such as www.sqad.com (together “Websites”), (ii) may come in contact with any of our marketing and sales related efforts or activities (“Sales Activities”), or (iii) may use our solutions’ media planning and cost reporting tools and dashboards (together “Planning & Cost Tools”). The purpose of this Privacy Policy is to inform you of SQAD’s privacy practices, particularly how we collect, use, share and secure the Personal Information we may collect. It also describes your choices regarding use, access, deletion, and correction of your Personal Information. We will review the notice regularly and publish updates as required by law, statute and/or regulation where your rights will be no less than what is required by law, statute, and/or regulation.

As used in this Privacy Policy, “Personal Information” means information that relates to an identified individual or to an identifiable individual. We believe in providing strong privacy protections to any individual whose information we may process in any capacity – because we believe privacy is a fundamental right, not something that should depend on where you may live. To live up to that principle, we treat any data that relates or is linked to an identified or identifiable individual as “Personal Information” regardless of that individual’s location.

Please note that:

Not all the information set out in this Privacy Policy may apply to you. Our interactions with you, and the choices you make regarding how you use SQAD, will determine which portions of the Privacy Policy apply to you and your Personal Information. Wherever we provide examples of information in this Privacy Policy, the examples are not intended to be an exhaustive list;
When you share Personal Information with us or when we collect Personal Information about you, we will use it in line with this Privacy Policy. Please read this Privacy Policy carefully. If you have questions or concerns about your Personal Information, please contact us at privacy@sqad.com; and
This Privacy Policy does not cover our clients’ use of your Personal Information outside of the products and services we may provide them. We are not responsible for the privacy practices of our clients. Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by third parties. Any such participation will be subject to the relevant third party's terms and conditions.

PERSONAL INFORMATION PROCESSED, PURPOSES AND LEGAL BASES OF PROCESSING

The following chart provides an outline of the categories of Personal Information we may process, including examples of what data points are included in each category, as well as the applicable purposes and legal basis of processing. Please note that often the same Personal Information is collected and processed for multiple purposes. For example, if you register for one of our events, we collect your Personal Information to enable your attendance, but we may also have the ability to use the same information for promotional purposes. As such, our collection and processing of your Personal Information and the applicable legal basis vary based on the context.

Category of Personal Information	Examples of data points	Purposes and Legal Basis of Processing
Contact Information	This information could include first and last name, email address, telephone number, business address, and title.	Contact Information is collected to support SQAD’s Sales Activities, to respond to your requests, provide support to customers, prospects and sales leads, market our solutions, and provide information about any events we host or sponsor. In these scenarios, Contact Information is generally shared directly by you, for example by completing a form on our sites, registering for one of our events or subscribing to one of our newsletters. Some information about you may be collected from publicly available resources. To the extent applicable and required from time to time, our lawful basis to process such Personal Information is your consent, or, if you are a customer, then based on our obligation to fulfill requirements mandated in our contracts to provide our solutions.
Account Information	This information could include business contact information such as name, email address, title, company information, country/geographic region, as well as credentials, such as user information and password, for our Planning & Cost Tools.	Account Information is necessary for SQAD to operate the Planning & Cost Tools, comply with our contractual and legal obligations, provide Customer support and effectively manage its standard business operations, such as providing billing and invoices to our Customers. In these scenarios, Account Information is generally shared directly by you or by our Customers in the course of their business relationship with SQAD. Our lawful basis to process this Personal Information is our legitimate interest in supporting our daily business processes and operations. Account Information is necessary to enable Customers and their designated representatives to access our Planning & Cost Tools. In these scenarios, Account Information is generally shared directly by you or by our Customers in the course of their business relationship with SQAD. Our lawful basis to process this Personal Information is based on our obligation to fulfill requirements mandated in our contracts to provide our solutions.
Cookie Data (First and Third Party tracking)	This information could include cookie IDs, Internet Protocol (IP) address, browser and device information, general location information and account log-in information.	Cookie Data may be necessary to enable our Websites and Planning & Cost Tools to operate efficiently, understand and improve your experience, ensure we remain compliant with local laws and regulations and protect ourselves against fraud, illegal activity and security risks, improve our Websites, Solutions and Planning & Cost Tools and ensure we are able to effectively monitor activity on our Websites and Planning & Cost Tools. Our lawful basis for this type of processing of Cookie related information is based on our legitimate interest to pursue these goals. Cookies and other tracking technologies may be used to collect information about your use of our Websites and Planning & Cost Tools so that they can provide advertising about products and services tailored to your interests on our Websites, or on other websites, and improve the features, quality and performance of our Reporting. To the extent applicable from time to time, our lawful basis to process such Cookie Data is your consent. For more information about how SQAD uses cookies please refer to the Section 6, “SQAD’s Use of Cookies and Similar Technologies” of this Privacy Policy.
Email Performance Information	This information could include data about your interaction with an email you may have received from us, including, for example whether you clicked on a link or opened the email	Email Performance Information may be collected to analyze and understand how you interact with our communications to report and improve our communications and Sales Activities intended to promote our Solutions. Our lawful basis for this type of processing of Email Performance Information related information is based on our legitimate interest to pursue these goals. It’s important to note that while this information is associated with the individual user, SQAD’s use of Email Performance Information is generally limited to aggregated and anonymous inferences drawn from the data collected.
Page Interaction Data	This information could include whether you click on links or banners, or information about your device or browser.	Page Interaction Data may be necessary to help us understand how you interact with our Websites to improve their performance, prevent fraud, illegal activity or security risks, improve our Websites and Planning & Cost Tools and ensure we are able to effectively monitor activity on our Websites. Our lawful basis for this type of processing of Page Interaction Information related information is based on our legitimate interest to pursue these goals. It’s important to note that while this information is associated with the individual user, SQAD’s use of Page Interaction Data is generally limited to aggregated and anonymous inferences drawn from the data collected.
Planning & Cost Tools Interaction Data	This information could include general usage information about how you use and interact with our Planning & Cost Tools, your click activity and most used features, the types of reports created and the general performance of the Planning & Cost Tools during a use session, as well as any feedback you may provide about the Planning & Cost Tools.	Planning & Cost Tools Interaction Data may be necessary to help us understand how you interact with our Planning & Cost Tools, to improve their performance, prevent fraud, illegal activity or security risks, improve our Websites and Planning & Cost Tools and ensure we are able to effectively monitor activity on our Planning & Cost Tools. Planning & Cost Tools Interaction Data may also be used to improve our Solutions. Our lawful basis for this type of processing of Planning & Cost Tools Interaction Information related information is based on our legitimate interest to pursue these goals. It’s important to note that while this information is associated with the individual user, SQAD’s use of Planning & Cost Tools Interaction Data is generally limited to aggregated and anonymous inferences drawn from the data collected.
Web Logs	This information could include information about your browser type, operating system, Internet Protocol (IP) address, click-activity and date/time stamps of your use.	Web Logs may be necessary to help us monitor out networks, Websites and Planning & Cost Tools, including to prevent fraud, illegal activity and security risks, improve our Websites and Planning & Cost Tools and ensure we are able to effectively monitor activity on our Websites and Planning & Cost Tools. Our lawful basis for this type of processing of Web Logs related information is based on our legitimate interest to pursue these goals. It’s important to note that while this information is associated with the individual user, SQAD’s use of Web Logs is generally limited to aggregated and anonymous inferences drawn from the data collected.

IP addresses are unique numeric identifiers that are assigned to each computer, mobile phone, tablet or other device accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by your Internet Service Provider (ISP), your IP address can be used to identify the device accessing the Website. Under certain circumstances, recipients, their legal representatives, and/or law enforcement authorities may be able to combine this with information disclosed by ISPs to determine the source of a particular communication. You knowingly and voluntarily assume any risks associated with such disclosure.

In addition to the information outlined above, we may also develop inferences drawn from the Personal Information we collect about you and we may collect or receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available information.

USE AND PROCESSING OF YOUR PERSONAL INFORMATION

In addition to the uses outlined in Section 2, “Personal Information Processed, Purposes and Legal Bases of Processing”, SQAD may use your Personal Information and any inferences drawn from such Personal Information in the following ways:

To recognize you when you visit our Websites, interact with our Sales Activities or use our Planning & Cost Tools;
To promote our Solutions and improve our Sales Activities, including sending marketing and promotional materials and information related to our Solutions to Customers, prospects and sales leads;
To improve our Websites, Sales Activities, Solutions and Planning & Cost Tools;
To promote the security of our Solutions, Websites, Sales Activities and Planning & Cost Tools;
To conduct analysis;
To respond to inquiries from individuals, third parties and government entities;
To enable us to fulfill contractual requirements provided for in our Customer agreements;
For internal administrative purposes; and
And otherwise required by applicable laws and regulations.

TO WHOM AND HOW WE MAY SHARE PERSONAL INFORMATION

SQAD does not disclose Personal Information to third parties, except as strictly necessary for our business purposes to operate, support, maintain and improve our Websites, Sales Activities and Planning & Cost Tools. To the extent we voluntarily share any Personal Information, we ensure it is protected by the recipients in a manner consistent with our own policies and standards.

We may share your Personal Information with:

Service Providers – companies we have contracted to provide us services such as IT and system administration, infrastructure and hosting services, research and analytics, support and quality assurance, security and other services, for the purposes and pursuant to the legal basis described above. You can request a list of our Service Providers, what Personal Information they receive and for what purposes by contacting us. You can find our contact information in Section 10, “How to Contact SQAD” of this Privacy Policy.

Affiliates – such as a parent company, sister companies, subsidiaries, joint ventures or other companies under common control, to the extent necessary to operate, maintain and improve our Solutions. You can request a list of our Affiliates, what Personal Information they receive and for what purposes by contacting us. You can find our contact information in Section 10, “How to Contact SQAD” of this Privacy Policy.

Third Parties involved in a Corporate Transaction – in the event that SQAD is acquired or merged with another company, or in the event of a reorganization, dissolution or other fundamental corporate change.

Additional disclosures to Third Parties – we may be able to share your Personal Information with other third parties based on your consent, or, in limited circumstances without your consent, for example, to the extent we are legally required to share such Personal Information as further described in this Section or in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

We may be legally required to disclose your Personal Information:

If a government entity, tribunal, law enforcement or regulatory agency requires such disclosure (for example as part of an ongoing investigation, subpoena, similar legal process or proceeding);
As otherwise required under any applicable law, regulation, or rule; and
If we believe, in good faith, that such disclosure is necessary to protect or defend our rights or the rights of others, to assist in an investigation or to prevent illegal activity.

In addition to the above, we may share Personal Information about you with others to the extent you consent to such sharing.

TRANSFERRING PERSONAL INFORMATION GLOBALLY

Please be aware that the Personal Information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction. While some of your Personal Information may be temporarily stored or cached in a storage facility closer to you, to ensure our Websites and Planning & Cost Tools are efficient and responsive, SQAD generally stores all Personal Information collected through our Websites, Sales Activities and Planning & Cost Tools in the United States. As a global company, we have employees in various countries, including in the United States, the Philippines, and the United Kingdom. Our employees at these locations may be required to access your Personal Information to support our operations. The level of data protection established in some of these locations, such as the United States, may be lower than the one established in the European Union or other jurisdictions that have enacted strong privacy laws and regulations. We take measures to ensure that your Personal Information is stored safely with us, meeting regulatory privacy and security requirements imposed on European Union businesses. We also ensure that any other recipient of your Personal Information offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission or other applicable regulator.

SQAD’S USE OF COOKIES AND SIMILAR TECHNOLOGIES

Like many other companies, we use cookies, pixels and software development kits (SDKs) to learn and remember things about you, to improve your experience and our Websites, Sales Activities and Planning & Cost Tools. To the extent these technologies collect Personal Information Section 2, “Personal Information Processed, Role, Purposes and Legal Bases of Processing” and Section 3, “Use and Processing of Your Personal Information” of this Privacy Policy explains how that Personal Information is collected and used. Except to the extent explicit consent for the use of cookies and similar technologies may be required by applicable laws or regulations, continued use of our Websites and Planning & Cost Tools will constitute implicit consent to SQAD’s use of such technologies.

Cookies are small alphanumeric text files that are automatically assigned to visitors of a particular website or page. Cookies may be temporary and only reside on your browser or device during your visit, in which case they are called “session cookies,” or they may remain on your browser or device until you delete the cookie or it automatically expires, in which case they are called “persistent cookies”. Pixels are lines of code that sit within a webpage that are used to record information about a visit to that webpage.

SQAD uses the following types of cookies:

Type of Cookies	Purpose of the Cookies
Performance and Analytics Cookies	These types of cookies provide aggregated and individual information about how individuals interact with or use our Websites or Planning & Cost Tools. The information collected allows us to optimize performance, improve efficiency and responsiveness, improve our Websites and Planning & Cost Tools, enhance safety features and prevent fraud and illegal activity.
Google Analytics (Persistent)	This type of cookie allows us to gather information about your visits to our Websites or Planning & Cost Tools remains on your browser or device until you delete it or it automatically expires.
Google Analytics (Session)	This type of cookie provides information about your visit on our Websites and Planning & Cost Tools that may include the cookie. We do not retain this data as it is deleted upon closing of your browser, and therefore we cannot share it with any third parties.
Authentication and Security Cookies	These types of cookies support log-ins in our Planning & Cost Tools and allow us to enable faster and more secure access to our Planning & Cost Tools.
Social Media Sharing	These types of cookies help with the Websites’ functionality. These are third party cookies, and they allow you to share comments, pages, bookmarks, and likes, and help to provide access to social networking tools more easily.
Social Media Widgets	Social media widgets we use on this Website include YouTube, LinkedIn, Facebook and Twitter. These social media widgets collect information about your visit to our Websites and your use of the social platform services (for example, buttons or likes) on our Websites. We do not share information with these social platforms, however please keep in mind that these social networks collect the data related to your visit on our Websites and any direct interaction with the social widget.

If you have more questions about the cookies and other technologies used by SQAD, what Personal Information they receive and for what purposes you can contact us for more information. You can find our contact information in Section 10, “How to Contact SQAD” of this Privacy Policy.

The use of cookies is now standard for most websites. However, if you are uncomfortable with the use of cookies, you can manage and control them through your browser.

To find out how to manage cookies on popular browsers visit these pages:

Google Chrome

Microsoft Windows Explorer

Microsoft Edge

Mozilla Firefox

Apple Safari

If the browser you use is not listed here, you should be able to find this information on the browser developer’s website. Please be aware that any changes or preferences you set are only valid for the browser you set them on, if you are using different browsers or devices you will need to adjust your preferences on each individual browser or device.

Please note that by disabling the use of cookies on our site may prevent you from accessing or using some of our Websites’ or Planning & Cost Tools’ features.

SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

We are committed to earning and keeping your trust. We understand the need for your Personal Information to remain secure and private, and we have implemented security practices and procedures designed to safeguard your information.

Please remember that you also play a valuable part in data security. You should never share your account user name and/or password with anyone. If you feel your user name and/or password has been compromised, you should change it immediately. After you have finished using our Website(s) and Planning & Cost Tools, you should log out of your Account and exit your browser so that no unauthorized persons can use our Website or Planning & Cost Tools under your name or Account. If you have any questions about the security of your Personal Information, you can contact us at privacy@sqad.com.

We may retain your information for as long as your account is active or as needed to provide you services and to fulfill the purposes for which the data was collected or as otherwise set forth in other agreements. We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements.

COLLECTION OF INFORMATION FROM CHILDREN

None of our products or services are intended for use or purchase by children. Accordingly, we do not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us at privacy@sqad.com.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, policies or other internal or external changes, as well as to comply with new legal requirements. Any changes will be posted as soon as they go ingo effect. If we make updates, we will update the “effective date” listed at the top to help you understand when changes were made. To stay informed of any such updates, we encourage you to refer back to this Privacy Policy regularly. Please note that any translation of this Privacy Policy is intended solely to facilitate your access to this information. The English version is the only official version of this Privacy Policy and any translation inaccuracies or discrepancies are not binding and have no legal effect for compliance or enforcement purposes.

HOW TO CONTACT SQAD

If you have any questions, concerns or comments about this Privacy Policy, or you believe your Personal Information has been used in a way that is not consistent with the Privacy Policy or your choices, you can contact our Privacy Team, via postal mail or email, at:

Privacy Team
SQAD
303 Broadway, Suite 130
Tarrytown, NY 11741
privacy@sqad.com

We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws. However, if you believe we have not been able to assist you, nothing in this Privacy Policy limits or attempts to limit your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local Data Protection Authority or other agency with jurisdiction over privacy related matters.

FOR CALIFORNIA CONSUMERS

Pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), this section provides additional information to California consumers whose Personal Information we may collect. This section supplements the information provided elsewhere in the Privacy Policy and applies solely to California consumers.

Notice of Collection and Use of Personal Information

As described elsewhere in the Privacy Policy in more detail, we may collect, and may have collected during the past 12 months, the following categories of Personal Information about you:

Identifiers: including real name, postal address, unique personal identifier (such as cookies, mobile ad identifiers and similar technology), internet protocol address, email address, account name, and other similar identifiers
Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history and information regarding your interaction with websites, applications or advertisements
Geolocation Data
Inferences: inferences drawn from any of the information identified above

We may use, and may have used during the previous 12 months, these categories of Personal Information for the purposes described in our Privacy Policy (under Section 2, “Personal Information Processed, Purposes and Legal Bases of Processing” and Section 3, “Use And Processing of Your Personal Information”), including for the business purposes that are specified in the CCPA.

Sharing/Sale of Personal Information

As further described in our Privacy Policy Section 4, “To Whom and How We May Share Personal Information”, from time to time (including during the previous 12 months), we may share each of the above categories of Personal Information with third parties for the business purposes that are specified in the CCPA.

Under the CCPA, the term “sell” is broadly defined to include several different kinds of data sharing with third parties for monetary or other valuable consideration. Under this definition, we may sell your Personal Information in exchange for monetary or non-monetary consideration in the following way, as described in our Privacy Policy under the heading “To Whom and How We May Share Personal Information”: We may allow certain third party online advertising services to collect your Personal Information via automated technologies on our sites or services. We may share the following categories of Personal Information for online advertising purposes: Identifiers and/or Online Activity.

You have the right to opt out of these disclosures of your information, as detailed below.

We do not sell the Personal Information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

California Consumer Privacy Rights

You have certain choices regarding your Personal Information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain Personal Information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your Personal Information.

How to Submit a Request. To submit an access or deletion request, or to opt-out of the sale of your Personal Information, please either email us at privacy@sqad.com or mail us at the address provided above in Section 10, “How to Contact SQAD”.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If you have an account with us, we may seek to verify your identity by requiring you to sign in to your account and/or answer security questions related to your account. If you do not have an account with us, or an email address on file with us (such as if you signed up to receive our marketing emails), then there may not be a reasonable method by which we can verify your identity to the level of certainty required by the CCPA. This is because historically we have not linked device identifiers or advertising IDs to named actual persons. Accordingly, if you do not have an account with us, or an email address on file, and you request access to or deletion of your Personal Information, we will not be able to process your request at this time. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, then (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This section is available in alternative formats upon request. To request it in an alternative format, please either email us at privacy@sqad.com or mail us at the address provided above in Section 10, “How to Contact SQAD”.