Effective Date: January 1, 2020
We refer to the above websites and all related websites as “sites” and to each of them as a “site.” When we refer to “we,” “us,” or “our,” we mean Goodway Group, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.
- GENERAL DISCLOSURES
- WHAT INFORMATION WE COLLECT
- HOW WE USE YOUR INFORMATION
- WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION
- COOKIES POLICY
- HOW TO RESTRICT COOKIES
- THIRD-PARTY ADVERTISING AND ANALYTICS
- LINKING SITES
- SOCIAL MEDIA
- HOW LONG WE RETAIN YOUR INFORMATION
- OPT-OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS AND ADVERTISING
- DIGITAL ADVERTISING ALLIANCE COMPLIANCE DISCLOSURE/
- CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION
- CALIFORNIA CONSUMERS
- NEVADA CONSUMERS
- CONTACT US
- TABLE OF COOKIES
We serve as a partner to agencies and brand marketers providing managed services for programmatic, social, search and other types of digital media. We work with many demand-side platforms (DSPs) and data partners to create custom media plans and executions for our clients. At the same time, we are committed to protecting the privacy of online consumers. We have worked with our third-party ad-serving technology providers to ensure that we adhere to the privacy guidelines created by the Digital Advertising Alliance (DAA).
Business information. The sites and our Services are not intended for use by consumers or private individuals. We collect your business contact information, such as your full name and your business name, email address, telephone number, address and other work-related information you provide to us in the course of providing our Services to you or your organization.
We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.
WHAT INFORMATION WE COLLECT
1. Information You Provide To Us Directly
Goodway Group may collect different information from or about you depending on the manner in which you use our sites or Services. The following examples are provided to help you better understand the information we may collect through your use of the sites or in the course of us providing our Services.
For Individuals: We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:
- Identity Information includes first name, middle initial, last name, date of birth, gender, username or similar identifier.
- Contact Informationincludes personal mailing address, email address, telephone number.
- Financial Informationincludes bank account information and payment card details.
- Transaction Informationincludes details about the products and services you have purchased from us and the corresponding transactions.
- Technical Informationincludes, cookie information, location pixel, browsing time, website history, internet protocol (IP) address, your login data, time zone setting and location (geocodes), geolocation data, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Information includes your username and password, your preferences.
- Usage Informationincludes information about how you use our website, products and services.
- Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2. Information Received Through Third-Party Platforms
You may access our sites through third-party platforms, such as Facebook. If you use our sites on or through a third-party platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such third parties or third-party platforms. You should review such privacy policies, terms and other agreements.
3. Information We Collect From Third Parties
Goodway Group collects certain information about or relating to you from third parties who directly or indirectly collected the information from you, including identity information such as age, nationality and racial or ethnic origin and social media information such as social media contact, history and account.
4. Collection Of Technical Information And Usage Information
When you access Goodway Group’s sites, we automatically collect certain information. This information may include without limitation: (a) technical information about your computer or Wireless Device, such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with Goodway Group’s sites, including pages accessed, referring website address(es) time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of Goodway Group’s sites (collectively “Usage Information”).
HOW WE USE YOUR INFORMATION
We may use information about you for a number of purposes, including:
1. Advertising And Marketing
- Creating customized advertisements to display for you on participating websites and to analyze if the advertising resulted in a desired action, such as sales; and
- Communicating with you about opportunities, products, services, promotions, discounts, incentives, and/or rewards offered by us and select partners. If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us. To learn about your choices regarding interest-based advertising and cross-device tracking, please see OPT-OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS AND ADVERTISING.
2. Providing, Improving And Developing Our Services
- Reviewing and analyzing user browser and wireless device technical information;
- Reviewing user activity across sites (for example, Goodway Group analyzes trends, user traffic and usage information to determine the performance of content, research reports or events);
- Displaying your historical transaction information;
- Providing, maintaining and improving our Services;
- Developing new products and Services;
- Delivering the information and support you request;
- Improving, personalizing and facilitating your use of our Services; and
- Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services.
3. Communicating With You About Our Services
- Responding to questions or concerns; and
- Sending you information we think you may find useful or which you have requested from us about our Services.
3. Protecting Our Services And Maintaining A Trusted Environment
- Enforcing our Terms of Service or other applicable agreements or policies;
- Verifying your identity;
- Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
- Fulfilling any other purpose disclosed to you in connection with our Services;
- Analyze trends and user traffic, track purchases and usage information; and
- Contacting you to resolve disputes and provide assistance with our Services.
4. Other Uses
- For any other purpose disclosed to you in connection with our Services from time to time.
THIRD-PARTY ADVERTISING AND ANALYTICS
HOW LONG WE RETAIN YOUR INFORMATION
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable laws, and we will establish a document/information retention policy to govern our retention of such information. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
In some circumstances we may anonymize or de-identify your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows Goodway Group to keep the non-personal information. For example, Goodway Group will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow Goodway Group to maintain a level of information that helps us develop and improve our sites and Services.
OPT-OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS AND ADVERTISING
If you no longer wish to receive advertising based on your interests or other web-browsing behavior, the online advertising industry provides websites from which you may opt out of interest-based advertising from Goodway Group and other companies that participate in industry self-regulatory programs. The US-based opt out pages are www.aboutads.info/choices and www.networkadvertising.org/choices. The European based page is www.youronlinechoices.com. In Canada, use www.youradchoices.ca/choices.
For mobile apps, you can opt out of Goodway Group using information about your usage of mobile apps that are targeted to your interests by using your device settings, for most devices. We are not able to directly access the Mobile App Opt Out on devices that offer it. To learn how to use the mobile app opt out, consult your device instructions. To find information on opting out on mobile devices please visit http://www.networkadvertising.org/mobile-choice.
You may also opt-out of receiving marketing and promotional messages from Goodway Group, if those messages are powered by Goodway Group, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.
DIGITAL ADVERTISING ALLIANCE COMPLIANCE DISCLOSURE
We comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA): (https://www.aboutads.info/). As part of this service, our online advertisements are sometimes delivered with icons to help you choose and control how your data is supplied and used.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under CONTACT US. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.
The California Consumer Privacy Act (“CCPA”) permits residents of California to have the following additional rights. For more information, or if you have questions, you can contact us using the information provided under CONTACT US. For your protection, Goodway Group is required to collect certain information from you to verify your identity before we respond to any request submitted by you. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by Goodway Group for its files.
1. California Residents Have The Right To Request Goodway Group Disclose What Information It Collects, Uses And Discloses
California residents have the right to request that Goodway Group disclose what personal information Goodway Group collects, uses and discloses about them now and in the last twelve (12) months. The categories of personal information Goodway Group collects about California residents are listed above under WHAT INFORMATION WE COLLECT. If you are a California resident and would like to request the personal information that Goodway Group collects, uses and discloses about you, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US.
2. California Residents Have The Right To Request The Deletion Of Their Personal Information Maintained By Goodway Group
California residents have the right to request that Goodway Group delete the personal information Goodway Group maintains about them. Goodway Group will make every effort to comply with California residents’ requests to delete their personal information, however, certain laws or other legal requirements might prevent some personal information from being deleted. If you are a California resident and would like to request the deletion of your personal information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US. To verify any request to delete personal information, you will be required to provide the information contained in the request form. Failure to do so could result in Goodway Group’s inability to comply with your request.
2. California Residents Have The Right To Non-Discrimination For The Exercise Of Their Privacy Rights Under The CCPA
Under the CCPA, California residents have the right not to receive discriminatory treatment by Goodway Group for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents will make it so that Goodway Group is no longer able to provide those residents with certain services. For example, if, at the request of a California resident, Goodway Group deletes all of the California resident’s personal information that it maintains, Goodway Group will no longer be able to send marketing communications to that California resident.
3. DO NOT SELL MY PERSONAL INFORMATION: California Residents Can Opt-Out Of The Sale Of Their Personal Information
The CCPA provides California residents the right to opt-out of the sale of their personal information by Goodway Group. If you are a California resident and would like to opt-out of the sale of your personal information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US. California residents may choose to use an authorized agent to exercise their right to opt-out of the sale of their personal information, subject to the requirements in the below section on designating an authorized agent.
4. California Residents Can Designate An Authorized Agent To Make A Request Under The CCPA On Their Behalf
California residents can designate an authorized agent to make requests under the CCPA related to the residents’ personal information. Goodway Group can deny any request made by an agent who does not submit proof that he or she has been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided under CONTACT US.
5. Do Not Track
Nevada law provides Nevada residents the ability to opt-out of the sale of their personally identifiable information collected by Goodway Group. If you are a Nevada resident and would like to opt-out of the sale of your personally identifiable information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US.
For your protection, Goodway Group is required to collect certain information from you to verify your identity before we respond to any request submitted by you. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by Goodway Group for its files.
Goodway Group, Inc.
261 Old York Road, Suite 930
Jenkintown, PA 19046
(877) 274-9881 (toll free)
The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Singaporean Personal Data Protection Act (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”) impose requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).
1. Personal Data
In this International Policy, personal data is as defined by applicable Canadian, Singaporean and European Union law. It generally means any information about an identifiable individual. It may include your name, age, mailing address, residential phone number, or e-mail address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, security clearances and computer data (IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views).
2. Collection Of Personal Data
We collect personal data from the site(s), as well as through correspondence, faxes, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide the Services and other lawful purposes.
We (and our affiliates and authorized service providers) may collect, store and use the information discussed above in WHAT INFORMATION WE COLLECT.
We also may collect information about your computer and your visits to the site(s) such as your cookie information, location pixel, browsing time, website history, internet protocol (IP) address, your login data, time zone setting and location (geocodes), geolocation data, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may use this information in the administration of the site(s), to improve the usability of the site(s), to provide better service, to send you newsletters, updates, marketing communications, and other information that may be of interest to you. We also use outside services such Google Analytics to gather data about visitors to our site(s). We may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, usage and related information.
We often collect personal data from you or from third-parties, and as agents on behalf of third parties, where we have obtained the requisite consent to do so or as otherwise permitted by law. Third parties include, as examples, organizations for whom we provide services to you or on your behalf (such as payment processors and systems development and maintenance organizations).
Where we are the Data Controller with regard to that data you may exercise your rights as data subject, including the right to object to the processing of your personal data when it is processed based on legitimate interests as provided in this International Policy below.
2. How We Use Personal Data
In addition to the uses described above in HOW WE USE YOUR INFORMATION, as a general matter, we collect your personal data primarily to provide services to our customers, for administrative or management requirements and to enhance our relationship with customers.
Goodway Group collects and uses your personal data to operate its site(s), deliver the Services you have requested and to provide services to our customers, including advertising services.
Goodway Group may also use your personal data to inform you of other products or services available from Goodway Group and its affiliates. Goodway Group may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Goodway Group may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal data (e-mail, name, address, telephone number) is not transferred to the third-party. Goodway Group may share data with trusted partners to help perform statistical analysis, send you email or postal mail, or provide customer support. All such third-parties are prohibited from using your personal data except to provide services to you, and they are required to maintain the confidentiality of your data.
Goodway Group may keep track of the websites and pages our users visit within Goodway Group, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within Goodway Group to customers whose behavior indicates that they are interested in a particular subject area.
Goodway Group will disclose your personal data, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Goodway Group or the site; (b) protect and defend the rights or property of Goodway Group; and, (c) act under exigent circumstances to protect the personal safety of users of Goodway Group, or the public.
3. The Basis On Which We Process Your Personal Data
We rely on the following legal grounds to process your personal data, namely:
- Performance of a contract – We may need to collect and use your personal data to enter into a contract or to perform a contract that you or your Goodway Group has with us.
- Consent – Where required by applicable laws, we will rely on your consent for collecting your personal data.
We will only process personal data for a specific purpose or for any other purposes specifically permitted by applicable data protection legislation.
4. Obtaining Consent
Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal data for any purpose. You may provide your consent to us orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive personal data in our capacity as a data controller. We may also share data with third-party partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given. From time to time, we may collect, utilize or disclose your personal data based on your consent and as otherwise permitted by law.
When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide Services to you and to maintain our relationship.
We remain responsible for all personal data communicated to third parties for processing. As such, we ensure that third-parties that are engaged to provide products or services on our behalf and are provided with personal data are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal data for any purpose other than the purpose for which the personal data was communicated.
We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.
7. Retention Of Personal Data
We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal data. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
8. Access And Rights To Your Personal Data
Subject to the exceptions provided by the applicable law, we will make available to you any of your personal data that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. If you are a located in the European Economic Area (“EEA”), the GDPR provides you rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided. Simply send your request, using the Request Form provided, to the Privacy Officer listed below. Please be as specific as possible in your request so that we can meet the applicable time lines. REQUEST FORM
If you are a located in the EEA you also have the right to lodge a complaint to your Supervisory Authority.
9. Response Times
We will make every reasonable effort to respond to each of your written requests no later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.
We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
11. Identifying You In Connection With Requests
We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use or disclosure of your personal data in our possession. Any such information shall be used only for this purpose.
12. Opt-Out And Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving certain information. Users may opt-out of using the instructions located in e-mails sent by Goodway Group or by contacting us using the information under Contact.
We will use reasonable efforts to ensure that your personal data is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal data, unless such a process is necessary. In order to help us maintain and ensure that your personal data is accurate and up to date, you must inform us, without delay, of any change in the data you provided to us.
You can at any time, challenge the accuracy or completeness of the personal data we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal data we have on you is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal data.
We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
For residents of the EU and Singapore:
GSM: +31 (0)623214871
For residents of Canada:
Goodway Group, Inc.
261 Old York Road, Suite 930
Jenkintown, PA 19046
(877) 274-9881 (toll free)