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Effective February 18, 2014

INTRODUCTION:

At iovation Inc. we recognize that privacy is important. This iovation PRIVACY POLICY ("Policy") applies to the collection of data by iovation Inc., its subsidiaries, and affiliates (collectively, "iovation").

HOW DOES IOVATION COLLECT INFORMATION?

iovation collects information in two different ways. First, iovation may collect information from users of this website (the “Site”). Second, iovation receives information from its subscribers about devices that connect with websites operated or controlled by those subscribers and utilizes such information to assist the subscribers in fraud detection and prevention (the "iovation services"). We collect different information through each method.  This Privacy Policy only covers information collected through the Site, and does not cover any information collected elsewhere online  or offline by iovation, including the iovation services (unless specifically stated).

WHAT INFORMATION DO WE COLLECT ON THE SITE AND WHY?

iovation may ask you to register and provide personally identifiable information, which is information that may reasonably be used to identify you as a specific individual, such as your name, email address, mailing address, and phone number, when you request our white papers, order email newsletters, or respond to a marketing campaign. The information gathered is used to qualify you as a potential client and may be used to contact you regarding offerings specific to iovation's products and services. We follow strict best practices for email marketing and customer contact.

We may also automatically or passively collect information and statistics about connections to the Site (“Usage Information”) using a variety of technologies (including cookies, web beacons, and embedded scripts), and we may use third party service providers for these purposes. We use this information to enhance the user experience on the Site and to identify frequent visitors. Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to the Site, the search terms you entered into a search engine that lead you to the Site (if applicable), all of the areas within our Site that you visit, and the time of day you visited the Site, among other information. Usage Information also includes the IP address or other unique identifier (“Device Identifier”) for any device used to access the Site. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information. 

A cookie is a data file placed on a device when it is used to visit a Site or otherwise access our online content and may be used to remember you and your preferences and track your visits to our web pages, amongst other purposes. If you choose to disable cookies on your device, some features of the Site or our content may not function properly. Web beacons are invisible images or programming code that may be included on the Site and in our e-mail messages and that may be used, for instance, to count visitors to the Site, monitor how users navigate the Site, and count how many e-mails that were sent were actually opened or how many links were accessed. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

Third parties may collect personal information about you, including but not limited to your online activities over time and across different Web sites, when you visit the Site or other online Web sites and services.

WHAT INFORMATION DO WE COLLECT FROM THIRD PARTIES?

We may receive information about you from third parties. For example, if you are on another web site and you opt-in to receive information from iovation, the other web site will forward your contact and other information to us so that we may contact you as requested.

We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information.

DOES IOVATION USE ANALYTICS SERVICES?

iovation works with certain third parties (such as analytics companies) to provide us with information regarding Site traffic and usage. Some of these parties may collect personal information when you visit the Site or other online websites and services. We may provide these third parties with your Device Identifier, Usage Information, and related information about you, and these third parties may set and access their own tracking technologies (including cookies, web beacons, and embedded scripts) on the Site and elsewhere online. We are not responsible for the privacy practices of these third parties and this Privacy Policy does not cover those practices.

WITH WHOM DO WE SHARE INFORMATION COLLECTED ON THE SITE?

We may share the information you provide with our business partners acting on our behalf for the uses described above. We do not share your personal information with third parties or affiliates for those third parties' or affiliates’ marketing purposes unless you consent to such sharing.

iovation may also disclose personally identifiable information to third parties as permitted or required by law. These third parties could include government entities, courts or other entities (in response to subpoenas and other legal processes), and those with whom a subscriber may request us to share information.

iovation may also share information, including personal information, with its affiliates, primarily for business and operational purposes. iovation may disclose and transfer your personal information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; (ii) if iovation (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of iovation’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.

HOW LONG IS THE INFORMATION RETAINED?

Information is retained for an indeterminate amount of time.

DO USERS HAVE ACCESS TO THEIR INFORMATION?

iovation customers who visit this Site have access to the information we collect from them. Customers who wish to change or view information should contact their sales representative or contact iovation through email, phone or post.

SAFE HARBOR FRAMEWORK

iovation is committed to abide by the Safe Harbor framework as defined by the United States Department of Commerce regarding the collection, use and retention of personal information (the "Safe Harbor Principles").  iovation complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  iovation has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view iovation’s certification, please visit http://www.export.gov/safeharbor/.

HOW DOES IOVATION HANDLE DISPUTES ABOUT COLLECTED DATA?

iovation regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or iovation's treatment of user information by contacting us through this Site or by writing to us at Privacy Matters, c/o iovation Inc., 111 SW Fifth Avenue, Suite 3200, Portland, Oregon 97204 USA. When we receive formal written complaints at this address, it is iovation's policy to contact the complaining user regarding his or her concerns. iovation will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of data that cannot be resolved between iovation and an individual.

iovation has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by iovation, please visit the BBB EU SAFE HARBOR website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

OTHER SITES

This Policy applies to this Site only. iovation does not exercise control over any other Web sites, including those sites that subscribe to and use iovation's services. These other sites may place their own cookies or other files on user's device, collect data or solicit personally identifying information from the user. How any such information is handled lies strictly within the control of such third parties and is subject to their privacy policies. iovation has no responsibility for the confidentiality, protection or use of such information.

HOW WE OFFER OUR CUSTOMERS CHOICE

Users of this Site who do not want iovation Inc. to contact them or their company for marketing purposes by email, postal mail, fax and/or phone, may opt out by contacting our customer service or by sending email or writing to us at info@iovation.com.

iovation's subscribers who utilize iovation's fraud prevention services are responsible for providing appropriate notice and choice to their customers.

SECURITY OF YOUR INFORMATION

To help prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to help safeguard and secure the information we collect online. Access to customer information is restricted to authorized personnel only. iovation has adopted the following security measures to help ensure that the data is not accessible to unauthorized parties:

All employees of iovation who have access to the data are subject to Company policies that prohibit unauthorized transmission of data to third parties.

USERS RESIDING OUTSIDE THE UNITED STATES AND CONSENT TO TRANSFER

The Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States. By using the Site, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

CHILDREN’S PRIVACY

This Site is not intended for children, and iovation does not knowingly collect personal information from children. If iovation discovers that it has inadvertently collected personal information from anyone younger than the age of 13, it will delete that information.

POLICY MODIFICATIONS

We may modify this privacy policy from time to time. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we are going to use personally identifying information in a manner materially different from that stated at the time of collection we will notify users by posting a notice on the Site. Your continued use of the Site after the changes are posted constitutes your agreement to the changes. If you do not agree to the changes, please discontinue your use of the Site.

CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding iovation’s disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties (and in some cases affiliates) for their direct marketing purposes. Alternatively, the law provides that a company may comply, as iovation does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties and affiliates for those third parties’ and affiliates’ direct marketing purposes, and information on how to exercise that choice.  At this time, we do not share personally identifiable information with third parties or affiliates for those third parties’ or affiliates’ direct marketing purposes.  If we do so in the future, iovation will provide you with a choice prior to sharing your personally identifiable information with third parties and affiliates for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time iovation offers that choice, iovation will not share your information with that identified third party or affiliate for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: legal@iovation.com or write to us at the following mailing address: 111 SW Fifth Avenue, Suite 3200, Portland, Oregon 97204. You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

QUESTIONS?

Questions regarding iovation's privacy policy can be addressed to info@iovation.com.