Hindsight Technology Solutions, Inc. (“Hindsight,” “we,” “us,” or “our”) owns and operates hindsightsolutions.net (the “Site”) and provides contextual targeting technology-based services on behalf of its clients, which include online advertisers, publishers and other content providers (together we refer to the Site and any products or services we provide as the “Services”).
This Policy applies to all Personal Data and other information we may collect through the Site or our other Services in various ways, depending on whether you are a:
1. “Client” – A Site visitor or a publisher, advertiser or other content provider that has or is interested in seeking a contractual relationship with Hindsight; or
2. ”User” – Someone who visits our Clients’ websites and other third-party online properties and interacts with our contextual advertising Services.
By using the Site or any related Services you agree to the terms of this Policy.
Other websites, mobile applications, and other services, whether online or offline, may have their own privacy policies, and you should consult those accordingly. For example, the Services may contain links to external websites or other online services, including those embedded in third-party advertisements or sponsor information, which are not controlled by Hindsight. Hindsight is not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy policies of those third-party services for details. Hindsight may also allow interaction between the Services and other third-party online services such as social media providers. This may include plugins available through the Services that allow you to share information with persons outside of the Services. Please consult the privacy policies of such third-party providers before using them to make sure you are comfortable with the level of sharing.
The Services are intended for users eighteen (18) years of age or older. If you are not 18 years of age or older, you are not permitted to access or use the Services.
This Policy is effective as of: February 15, 2021.
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
1. POLICY CHANGES
Hindsight reserves the right to make changes to this Policy at any time. Since this Policy may change over time as we modify or expand our Services, we suggest you check back from time to time in order to understand how we treat your information. Our Policy’s effective date will always be set forth at the beginning and end of the Policy. Any changes will be immediately incorporated into this Policy, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.
Any change to this Policy is effective immediately. Your continued use of the Services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Services.
If any changes to this Policy materially affect how Hindsight treats or handles Personal Data that you have already provided to us or that has otherwise been collected by Hindsight, we will endeavor to provide you with notice in advance of such change(s) by highlighting the change on our Site. We will seek your prior consent to any material changes, if and where this is required by applicable data protection laws. If you do not opt-in, your information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected, or the information will be deleted.
2. INFORMATION HINDSIGHT MAY COLLECT
Personal Data is generally defined as information that, alone or in combination with other information, could identify, relate to, describe, reference, or reasonably could be associated with a particular individual, directly or indirectly. To provide some examples, depending on where you live, categories of Personal Data other businesses collect can include, but are not limited to, an individual’s name, address, phone number, email address, username and password, IP address, information specifically tied to an IP address such as browser or device information or other persistent online identifiers, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, is reasonably capable of being associated with you.
2.1 Client Information
Hindsight may collect certain Personal Data and other information directly from our Clients. For example, Hindsight will collect a Client’s contact details when a Client enters a contractual relationship with Hindsight and we will collect a password or other account access credentials when a Client creates a Hindsight account. When a Client sends us an email asking a question we will collect the information, including any Personal Data, that the Client provides in the email. We will also collect any Personal Data and other information that Clients choose to provide to us, such as any information contained in a message or form that a Client submits through our Site or via email. We may also collect Personal Data and other information from prospective Clients through publicly available sources. When using the Site, the Personal Data and other information Hindsight may collect includes your name, company name, business email address, and/or information associated with your Internet protocol (IP) address such as your browser, device, and location information to the extent such information is reasonably capable of identifying or being associated with you.
2.2 User Information
When Users interact with Hindsight Services that appear on our Clients’ websites and other third-party properties online, Hindsight may automatically collect certain information based on the IP address associated with the User’s computer, device, or browser. Such User information generally is not capable of being linked back to any specific individual and includes, but it not limited to, information about a User’s device and operating system, the web pages accessed by Users within our Clients’ websites, the link that led a User to a Client’s website, the dates and times a User accesses a Client’s website, event information (e.g., system crashes), general location information (e.g., city and state), hashed email addresses (when made available by the User), and gender (when made available by the User). To whatever extent such automatically collected User information is reasonably capable of identifying you or being associated with you, we will refer to it as device information and treat it as Personal Data. Hindsight requests that Clients obtain any necessary consent on our behalf where required to do so by applicable data protection laws and regulations, in order for Hindsight to collect this User Information.
3. HOW HINDSIGHT GATHERS INFORMATION
If you are a Client, we may collect Personal Data when you register an account for the Services, visit or use certain areas of the Site, submit questions, comments or other feedback through the “Contact Us” form on the Site, or voluntarily provide Personal Data to us in any other way.
If you are a User, we may collect other data in an automated manner whenever you visit our Clients’ websites and other online properties and interact with our Services, such as device information that may be Personal Data to the extent it is reasonably capable of identifying you. For example, when you access or use the Services, we and third parties that may provide certain functionality on or through the Services may engage, receive, collect, and store certain device information and other online identifiers through automatic data collection tools such as embedded web links and similar technology. These technologies may collect information including, but not limited to, your IP address, browser type, the date and time that you use the Services, referring/exit pages and URLs, number of clicks, unique identifiers related to your browser, and information about your device. This device information generally cannot be associated with you or other individuals, but if there is reason to believe that any device information could be linked to you, we will treat it as Personal Data.
The Services use such automatic data collection tools to serve relevant ad experiences to Users. Your browser may allow you to block, delete or otherwise disable these tools. However, if you disable them, the Services may not work properly.
4. HOW AND WHY HINDSIGHT USES YOUR INFORMATION
Hindsight only uses your Personal Data when we have a proper reason for doing so. For example, we may use your Personal Data as necessary to comply with a legal or regulatory obligation, to perform our contract with you or for our legitimate interests of providing the Services.
4.1 Client Information
- To communicate with you or take other actions, provide a demo of our Services, or take other actions at your request before entering into a contract;
- To maintain proper business records and other relevant records with respect to our contract or your use of our Services; or
- For customer service purposes and to send you communications regarding your Client account or additional uses of your Personal Data beyond the scope of this list and Policy, in response to any questions, comments, or other messages you submit to us, or for marketing, advertising, and promotional purposes in relation to other Hindsight products or services that we think may interest you.
4.2 User Information
- To provide the Services to you on behalf of our Clients;
- For the purposes of system administration, assisting in diagnosing problems with our servers, monitoring Hindsight system performance and traffic on or through the Services and to gather broad demographic information about Users;
- To deliver contextualized advertising content to you based on the articles and posts you view on our Clients’ websites and other online properties, which is tailored to your interests and includes information on new and relevant products, services or other third-party offerings;
- For the purpose of offering our Clients information about groupings of Users who share certain interests or preferences, and other User information relevant to the provision of our Services – for example, Hindsight may provide publisher Clients with information about the viewing and click-through patterns of the content they publish and it may provide advertiser Clients with information about conversion rates for analytics purposes; or
- Use of information based on your IP address in machine learning applications to generate aggregate and statistical metrics and to optimize its advertising Services.
5. PROCESSING BY THIRD-PARTY SERVICE PROVIDERS
Hindsight and certain third parties that provide services on our behalf will collect, process and use your Personal Data as described in this Policy and for the purposes set forth in this Policy.
Except as noted herein, Hindsight does not share or sell your Personal Data with any person or entity outside of Hindsight.
We may use and share any information, including Personal Data, that we receive with vendors and service providers retained as necessary for business purposes and other legitimate interests in connection with Hindsight’s provision of the Services. For example, this may include sharing Personal Data for purposes with your consent or approval as required under applicable laws and regulations, or for one or more of the following purposes:
- To better understand how Clients, Users, and any other individuals access and use our Site and Services, both on an aggregated and individualized basis, and for other research, analytical, and statistical purposes;
- To carry out our obligations and enforce our rights arising from any contracts related to your use of the Services, including for billing and collections;
- As necessary or appropriate to protect the rights, property or safety of Hindsight, our Clients or others;
- To respond to law enforcement requests and as required by applicable law, subpoena, court order, or other legal process or governmental regulations;
- As otherwise described to you at or before the point when we collect your Personal Data; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or to transfer some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us is among the assets transferred.
Hindsight will not disclose your Personal Data to law enforcement entities, government entities, or other persons unless permitted or required to do so by the following: (1) any lawful method or process by which a law enforcement entity is permitted to obtain such information; (2) a court order with sufficient notice to both Hindsight and the user so that either can contest disclosure; (3) the user has given informed, affirmative consent in writing to the specific disclosure to the specific person for a particular purpose; (4) Hindsight’s reasonable good faith belief that the Personal Data collected through the Services is evidence related to a crime against Hindsight or the applicable Client or User; and/or (v) an imminent danger of death or serious physical injury requiring disclosure of Personal Data, but only when the law enforcement entity requesting disclosure has applied for and received approval for a valid search warrant. Upon the written request of a law enforcement entity to preserve a Client’s or User’s Personal Data, pending receipt of a request or demand for such Personal Data pursuant to the conditions listed above, Hindsight will retain the relevant records and evidence for ninety (90) days from the date of the preservation request by the law enforcement entity, renewable for another 90-day period following a renewed written request by the law enforcement entity.
If you are a User, when you interact with our Services on our Clients’ websites and other third-party properties, we may provide advertisements to you based on your recent browsing behavior across different Client websites, browsers, or devices. For example, if you are viewing an article about a movie on one of our publisher Client’s sites, you may see an advertisement we provide that will feature information about tickets to movies in your area and include links to other articles or content about movies on the publisher’s site.
We adhere to the Self-Regulatory Principles set forth by the Digital Advertising Alliance (DAA), and the Interactive Advertising Bureau’s (IAB) Self-Regulatory Principles for Online Behavioral Advertising. In addition, Hindsight may work with advertiser Clients which are members of the Network Advertising Initiative (NAI), an association dedicated to responsible data collection use in digital advertising. To update your DAA AdChoices Opt-Out settings, select your region here: US, Canada, or Europe. To manage all NAI member sites’ settings, click here. If you opt-out using these industry-provided opt-out tools, you will still see ads but they will not be personalized based on your online activity. Please note that if you disable cookies or upgrade your browser after opting out, you will need to opt-out again. Further, if you use multiple browsers or devices you will need to execute these opt-outs on each browser or device, and there is no guarantee the opt-outs will prevent all personalized or behavioral advertising.
By providing to Hindsight the Personal Data and other data referenced above, you agree that Hindsight may use such Personal Data and other data in accordance with the terms of this Policy. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
6. WHERE PERSONAL DATA IS HELD
Personal Data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.
All Personal Data is stored on Hindsight computer systems which allow Hindsight to view the data. Our systems are hosted in the U.S. Your Personal Data may be disclosed to and processed by staff operating in the U.S. Disclosure will be to individuals who work for Hindsight, our subsidiaries, related companies, and companies with which we have contracted to process or store this data on Hindsight’s behalf. The individuals and organizations that receive Personal Data as a result of international transfers must follow our express instructions with respect to the use of Personal Data and they must comply with appropriate security measures to protect your information.
7. HOW LONG YOUR PERSONAL DATA IS HELD
We will retain your Personal Data while you use the Services or we are providing Services to you. Thereafter, we will keep your Personal Data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to keep records required by law; or
- for preserving, resolving, defending or enforcing our legal and contractual rights.
We will not retain your Personal Data for longer than necessary to fulfill the purposes set out in this Policy, or as otherwise permitted by applicable laws and regulations.
We will delete your Personal Data as soon as the respective purpose of use is not applicable anymore and no legal obligation to retain such information exists. If you have any questions about the security or retention of your Personal Data, you can contact us at firstname.lastname@example.org.
8. RIGHTS AND OTHER INFORMATION FOR INDIVIDUALS IN EUROPE
Some of our business partners and third-party vendors that provide services on our behalf may be based outside the European Economic Area (the “EEA,” which includes the European Union Member States, Iceland, Norway and Liechtenstein), Switzerland, and the United Kingdom (the “UK”) (collectively, the “EU”).
If you are located in the EU, you may have one or more of the following rights with regard to Hindsight’s collection, use and sharing of your Personal Data on or through the Services:
- The right to request access to the Personal Data we hold about you;
- The right to update and correct any inaccurate Personal Data Hindsight holds about you;
- The right, in certain circumstances, to object or withdraw any consent for marketing activities where we are relying on your consent to process your Personal Data;
- The right to request restriction of Hindsight’s processing of your Personal Data in certain circumstances (for example, if you contest the accuracy of the data);
- The right, in certain circumstances, to request the portability of Personal Data you provided to Hindsight; and/or
- The right, in certain circumstances, to request the erasure or deletion of Personal Data we have collected or maintain about you.
If you are a User and would like to understand how you can exercise any of your rights with respect to your Personal Data to the extent it is maintained by Hindsight, please submit a data subject access request by emailing us at email@example.com. If you are a Client or work on behalf of a Client, you may submit a data subject access request to the same email address and identify your relationship to the applicable Client so that Hindsight may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.
Under applicable data privacy and protection laws and regulations, Clients and Users located in the EU may have the right to lodge a complaint about Hindsight’s processing of your Personal Data with a supervisory authority. In particular, such individuals may lodge a complaint in the Member State where the individual lives or works or where the alleged violation took place.
If you reside within the EU, we will seek your consent before using your Personal Data to serve you relevant content and materials based on your personal preferences, interests, location and other information that you provide to Hindsight in connection with your use of the Services.
If you are located in the EU, we may need to share your Personal Data with third parties in other countries to provide our Services. This means that Personal Data collected within the EU could be transferred outside the EU. For example, your Personal Data may be transferred outside the EU:
- To our offices located in the U.S.;
- To services providers located outside of the EU; and/or
- Where there is an international dimension to the Services we are providing to you.
Transfers of Personal Data of individuals in the EU are subject to special rules under applicable data protection laws and regulations. This means we can only transfer Personal Data to a country outside the EU where:
- the European Commission has issued an ‘adequacy decision’ in relation to that country or international organization;
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law.
To protect your Personal Data, the Services use appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data and other information stored on our Services.
9. YOUR CHOICES
Depending on where you reside and in accordance with applicable laws and regulations, if you would like to request the ability to access, review, edit, delete or have us properly dispose of any of the Personal Data that Hindsight collected about you, if you would like to opt-out of receiving further information from Hindsight, or limit what we share, or if you otherwise wish Hindsight to cease using your Personal Data in the manners specified in this Policy (subject to any applicable legal exceptions), you can do so by emailing us at firstname.lastname@example.org or by calling us at 908 821 6865.
Any removal of content by Hindsight does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties, or federal, state or other applicable law may require maintenance of the content or information. Hindsight will do its best to accommodate your request, but we cannot guarantee we can remove all Personal Data from the specified uses. Therefore, please be as specific as possible in your request. If the request relates to information that Hindsight needs to make certain Services function properly for you, you may not be able to use those Services properly moving forward.
Hindsight reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your Personal Data.
Hindsight is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Data. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other requests, Hindsight will ask you to provide information that matches at least two pieces of Personal Data we store about you before responding to your request.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you would like to opt-out of receiving promotional emails from Hindsight, please follow the opt-out instructions at the bottom of the email or send Hindsight a detailed email at email@example.com.
Some browsers have a ”do not track” feature that lets you tell websites that you do not want to have your online activities tracked. Hindsight does not currently have the capability to process these kinds of technical requests. To learn about ways to opt-out of certain kinds of tracking for targeted advertising purposes, please visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific, and there is no guarantee these industry-provided opt-out tools will prevent all targeted advertising.
10. SECURING PERSONAL DATA
Hindsight implements, uses, and maintains industry standard technological security measures that are reasonably designed to help secure your non-public Personal Data from loss, unauthorized access or disclosure, both in storage and in transmission. Hindsight protects any Personal Data or other information it collects from you using various technologies and safeguards, including Secure Socket Layer (“SSL”), which is an encrypted communication protocol, and Transport Layer Security, the successor protocol to SSL. SSL and TLS are standard formats for transmitting secure data from your computer to Hindsight’s servers. SSL and TLS work by using a private key to encrypt data that is transferred over the SSL and TLS connection.
While Hindsight takes the issue of protecting your Personal Data seriously, you should exercise discretion in what information you disclose and/or transmit through the Services. Hindsight cannot guarantee that information sent over the Internet is fully secure. The transmitted information may be intercepted by others before it reaches Hindsight. If you are concerned about sending information to Hindsight over the Internet, please send the information by mail or call us to make other arrangements. Hindsight is not responsible for the security of information transmitted online.
11. CHILDREN’S PRIVACY
The Services are intended for individuals 16 years of age and older located in the United States. Hindsight neither collects nor sells the Personal Data of minors under 16 years of age.
The Services are not directed at, marketed to, nor intended for, individuals under 16 years of age. No one under the age of 16 is permitted to provide any information on or through the Services, and Hindsight does not knowingly collect any information from anyone under 16 years of age. If you are under 16 years of age, DO NOT use or provide any information about yourself on or through the Services, and DO NOT interact with any of the Services or their features. We do not and will not knowingly collect any information, including Personal Data, from any person under 16 years of age and Hindsight will take immediate steps to delete any such information if it is inadvertently received. If Hindsight learns that we have received Personal Data from any person under 16 years of age, Hindsight will delete that information. If you believe a person under 16 years of age used our Services without authorization in a way that Hindsight somehow received a persistent identifier such as a static IP address that is capable of identifying the person under 16, or any other information that could be considered Personal Data under applicable law, please contact us immediately at firstname.lastname@example.org. Again, any deletion by Hindsight does not ensure or guarantee complete or comprehensive removal of the information in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.
12. CALIFORNIA RESIDENTS
Applicable California privacy legislation permits visitors who are California residents to request certain information regarding Hindsight’s disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request to access such information, please contact Hindsight at email@example.com. Within thirty (30) days of receiving such a request, Hindsight will provide a list of the categories of Personal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. Hindsight reserves its right not to respond to requests submitted other than to the address specified in this paragraph.
13. TERMS AND CONDITIONS
The Hindsight Terms and Conditions (“Terms”) are incorporated by reference into this Policy. These Terms can be found at https://hindsightsolutions.net/terms-of-service/.
14. CONTACT INFORMATION
If you have any questions regarding this Policy, the Services, or your other interactions with Hindsight, please contact Hindsight at:
PHONE: 908 821 6865
MAIL: 300 Maple Avenue, South Plainfield NJ, 07080
Hindsight intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact us.
This Policy was last updated on February 15, 2021.