Privacy Policy

CPX Interactive, Inc. ("CPX Interactive ") owns and operates a proprietary marketing technology platform. Using unique phone numbers with personalization components combined with database management, CPX Interactive provides networks, advertisers, agencies, publishers (directly and indirectly "Clients"), and consumers with marketing automation services (the "Services"). Privacy is important to CPX Interactive and any information that is collected or used is limited to what is necessary to create and maintain innovative and reliable Services without compromising the The use of information collected through CPX Interactive Services shall be limited to the purpose of providing the service for which the Client has engaged CPX Interactive, Inc.

1. CONSUMER PRIVACY:

What information does CPX Interactive collect from consumers?

Web Services:

In general, when a consumer uses the CPX Interactive services by visiting the website or by calling a unique phone number associated with one of our Clients, CPX Interactive collects that consumer’s personal information if it is made available by the consumer or by a third party. This information includes limited personal data such as the caller’s name, address, phone number and email address. CPX Interactive will not knowingly collect personal information from children under the age of eighteen.

CPX Interactive or its Clients may also set up order forms, questionnaires or other mechanisms through which a consumer may be asked to provide certain information either online or via telephone or other communication medium. CPX Interactive will collect such consumer-supplied information. If, however, such communications are initiated by one of CPX Interactive’s Clients and the Client collects the information, CPX Interactive cannot be responsible for that information, though CPX Interactive does endeavor to ensure that its Clients maintain reasonable and appropriate privacy policies. Participation in any of these communications is purely voluntary; any consumer not wanting to participate or provide information may decline or terminate contact by navigating away from the web page or hanging up the phone.

When a consumer responds to or views an internet advertisement served by an CPX Interactive Client or visits an CPX Interactive website, CPX Interactive sends one or more cookies to the consumer’s computer to uniquely identify that consumer’s browser. As is common practice of doing business on the Internet, CPX Interactive uses cookies to improve the quality of the Services by storing user preferences and tracking user trends and also to determine how the Services are used and navigated. Cookies that CPX Interactive services on third party websites only collect data in the aggregate. While many cookies are automatically deleted at the end of a web session, CPX Interactive may use persistent cookies that remain on a specific browser after termination of a session. Any consumer may set their browser to refuse cookies or automatically clear cookies after termination of a session.

Phone Services:

CPX Interactive provides Client’s with unique telephone numbers to utilize on websites, emails, mobile or offline promotions. This enables CPX Interactive to both determine what the consumer was viewing when making a phone call and also personalize the experience for that consumer. CPX Interactive’s phone servers automatically collect the caller ID results when a consumer calls a number. CPX Interactive may also collect usage information from third-party databases, including the name, address and/or geographic location of the caller when such information is available.

In addition, CPX Interactive’s phone servers use software that may be employed on behalf of a Client to record calls. This recorded information may be evaluated in order to determine the quality of that call from the Client’s perspective and for training or other purposes. The recorded information also enables CPX Interactive to identify high-quality calls and collect additional usage data which help improve the Services and boost sales for Clients.

CPX Interactive may also use third-party services or technology for the transcription or analysis of such recorded information. In the event that CPX Interactive records a call on behalf of a Client, CPX Interactive will ensure that call participants are advised of the existence and intent of the recording in a manner consistent with applicable state and federal laws. CPX Interactive is not responsible in any way for the accuracy or validity of the content of any such recordings, and takes no steps to evaluate such accuracy or validity.

While CPX Interactive strongly encourages Clients to adopt responsible approaches to marketing, CPX Interactive is not responsible for the information practices of Clients or their partners. The collection, use, and disclosure of information by Clients and their partners are subject to their respective privacy policies, which may differ from CPX Interactive’s policy.

What are CPX Interactive’s reasons for collecting usage information?

CPX Interactive collects usage information when an internet user clicks on a link, creates a lead, initiates a phone call, receives a phone call, makes a purchase on a Client’s website, sends CPX Interactive or a Client a text message, receives a text message from CPX Interactive or a Client or makes an inquiry or a purchase during a phone call to a Client. Primarily, CPX Interactive collects this information for the purpose of attributing calls back to the originating ads or paying commissions to third parties and also to personalize the internet or phone user’s experience. If the internet user revisits the Client’s site directly or if the phone user calls the Client using the unique phone number again, CPX Interactive is able to continue to track the user’s activities on the Client’s site and compensate third parties that referred the user. CPX Interactive reserves the right to retain all data as long as may be reasonably necessary for accounting and audit purposes.

Like most standard Website servers, CPX Interactive uses log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. CPX Interactive may use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content. We do link this automatically collected data to other information we collect about you.

CPX Interactive also may develop predictive statistical user profiles of consumers’ needs and interests by collecting both internet browsing and online purchase data and phone user data. For improved audience targeting, some CPX Interactive services may use marketing technology to allow advertisers to supplement non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data.

CPX Interactive may collect personal information, such as consumers’ names, physical addresses, email addresses, phone numbers and other information in order to better target campaigns to meet user’s interests and to provide customized experiences as well as to provide the Services to Clients. CPX Interactive will share this information only as described herein. CPX Interactive will retain this data on behalf of Clients for as long as needed to provide the Services to that Client. CPX Interactive may also retain and use personal information as necessary to comply with any legal obligations, resolve disputes and/or enforce agreements.

Does CPX Interactive share usage information with others?

CPX Interactive does not share consumers’ personal information with companies or individuals outside of CPX Interactive except as described below:

  • CPX Interactive obtains consumer consent by requiring consumers to opt-in prior to CPX Interactive sharing information with CPX Interactive’s trusts third parties.
  • CPX Interactive provides information to its subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on CPX Interactive’s behalf. CPX Interactive requires these parties to agree to process such information only as necessary to provide CPX Interactive service, based on CPX Interactive’s instructions and in compliance with this privacy policy and other appropriate confidentiality and security measures.
  • CPX Interactive provides such information to its Clients to enable them to better provide consumers with information about products or services about which the consumer may be inquiring.
  • CPX Interactive may share personal information with our affiliates and other third parties to provide consumers with goods or services requested by them.
  • CPX Interactive may share personal information in connection with the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of CPX Interactive. In this case, consumers will be notified via a prominent notice on our website of any change in ownership or uses of consumer’s personal information, as well as any choices consumers may have regarding their personal information.
  • CPX Interactive may release personal information when it believes such release is appropriate to respond to a subpoena or to otherwise comply with the law, enforce or apply CPX Interactive’s Terms of Service and other agreements or protect the rights, property or safety of CPX Interactive or others. This includes exchanging information with other companies and organizations for fraud protection.

Can a consumer opt-out of providing information?

For consumers accessing the CPX Interactive Services through the internet, some of its cookies may have an "opt-out" option. This process does not remove the CPX Interactive cookie from a consumer’s system; it simply replaces the cookie with an opt-out cookies that does not contain any unique identifiers. Some of CPX Interactive’s cookies do not have an "opt-out" option, but consumers always have the option of blocking the use of cookies by changing a setting in their internet browser. CPX Interactive does not maintain a process for an individual consumer to opt-out of an CPX Interactive ad serving cookie. However, any consumer may set their browser to refuse cookies or automatically clear cookies after termination of a session.

With regard to phone services, consumers are able to submit their phone numbers to "do-not-call" registries. CPX Interactive will use its best efforts to observe do-not-call registries in any call campaign it performs or facilitates. However, consumers who have opted-in to receive such messages, either with a Client or with CPX Interactive, shall not be subject to any do-not-call restriction.

CPX Interactive also partners with third-party ad networks to either display advertising on the CPX Interactive website or to manage its advertising on other sites. These ad network partner(s) may use cookies and web beacons to collect non-personal information about a user’s activities on websites to provide the user with targeted advertising based upon its interests. If a user wishes to not have this information used for the purpose of being served targeted ads, a user may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt a user out of being served all advertising. The user will continue to receive generic ads.

Can a consumer access the personal information acquired by CPX Interactive?

CPX Interactive’s services are not directed toward individual consumers. CPX Interactive collects personal information only on behalf of our Clients to provide them a service. CPX Interactive may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. If you are a customer of one of CPX Interactive’s Clients and would no longer like to be contacted by a Client that uses the CPX Interactive Services, please contact that Client directly as that Client controls such data. CPX Interactive has no direct relationship with the individuals whose personal data it processes. An individual who seeks access to or otherwise seeks to correct, amend or delete inaccurate data should direct such inquiry to CPX Interactive’s Client. If you do contact CPX Interactive regarding such a request, CPX Interactive will respond within sixty days.

2. CLIENT PRIVACY

What information does CPX Interactive collect from its Clients?

CPX Interactive collects personal information from all of our Clients, which include networks, agencies, advertisers and publishers. The collection of this information is part of CPX Interactive’s normal business practices. Advertisers or their representatives will be asked to provide personal information through the sign up and registration process either directly by CPX Interactive or indirectly through a network or agency partner. This information may include name, address, phone number, hours of operation, coverage areas and email address.

Technologies such as: cookies, beacons, tags and scripts are used by CPX Interactive and our marketing partners, affiliates, or analytics or third party administrative. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 or Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here:http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

When using the CPX Interactive Services, Clients may enter third-party personal information on the platform, such as entering another user’s email. This information is only used to provide the Client access to the system and is not used for any other purpose.

How does CPX Interactive use its Clients’ information?

Much of the information collected from Clients is required to be collected for administrative needs, such as accounting and performance reporting. Periodically, CPX Interactive may use Clients’ information to communicate via email newsletters or other avenues to offer strategic marketing information and other communications to assist in business-related activities. Clients can opt-out from future communications by clicking on the unsubscribe links in such emails.

Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails from the advertiser. CPX Interactive is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is CPX Interactive’s policy to prohibit the sending of unsolicited or "Spam" e-mail by CPX Interactive or any of its marketing partners.

Except as otherwise provided, CPX Interactive keeps all personal data provided by individual Clients in strict confidence and treats such data with the same level of care and respect that CPX Interactive treats its own proprietary information. We do not sell, rent, exchange or barter any personal Client information to or with any third party for financial gain or marketing purposes. CPX Interactive may, from time to time, provide personal information to certain third-party administrative vendors for efficient purposes in providing administrative or program management services. Examples include an email service provider, marketing solutions provider and a blog provider. Any third-party vendor so used has agreed to protect the confidentiality of information provided by CPX Interactive.

CPX Interactive may also share information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of CPX Interactive.

CPX Interactive may release information when it believes release is appropriate to respond to a subpoena or otherwise comply with the law, to enforce or apply CPX Interactive’s Terms of Service and other agreements or to protect the rights, property, or safety of CPX Interactive or others. This includes exchanging information with other companies and organizations for fraud protection.

Can a client opt out of providing information?

Collecting information from Clients is required as a part of doing business. CPX Interactive’s primary intent in collecting information is for administrative purposes. However, it may periodically use collected information for marketing and communication purposes targeted to our Clients. Clients wishing not to receive such communications may do so by informing their designated CPX Interactive representative in writing at any time or by clicking on the unsubscribe link in the promotional communication.

When a Client logs on to any browser-based CPX Interactive reporting system, a cookie is placed within their computer. The cookie allows us to validate the Client’s identity and maintain the security and privacy of the Client’s account data. This cookie does not contain any personal information. It is required to log into CPX Interactive’s reporting systems and there is no method to opt-out of this cookie.

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DATA RETENTION

CPX Interactive retains all information for as long as a Client’s account is active or as needed to provide Services to the Client. CPX Interactive will retain and use a Client’s information as necessary to comply with any legal obligations, resolve disputes and enforce any agreements.

3. GENERAL:

Public Forums:

CPX Interactive’s website offers publically accessible blogs or community forums. Any user of the CPX Interactive website should be aware that any information provided in these areas may be read, collected and used by others who access these sites. In some cases, CPX Interactive may not be able to remove the personal information, in which case CPX Interactive will respond accordingly. CPX Interactive will only post Client testimonials with the Client’s consent to do so.

Our blog is also managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.

Links to other websites:

The CPX Interactive website and platform may include links to other websites whose privacy practices may differ from those of CPX Interactive. If a user submits personal information to any of those sites, that user’s information is governed by that third party’s privacy statements. Social Media Features and Widgets are either hosted by a third party or hosted directly on the CPX Interactive website. A user’s interactions with these Features are governed by the privacy policy of the company providing them.

How does CPX Interactive protect the security of personal information?

CPX Interactive takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. When a user enters sensitive information (such as login information), CPX Interactive encrypts the transmission of that information using secure socket layer technology (SSL). Any data stored on CPX Interactive’s servers is treated as proprietary and confidential and is not available to the public. CPX Interactive restricts access to personal information to those employees or third parties who have a need to know such information for the purpose of effectively delivering CPX Interactive products and Services by means of user login and password requirements. CPX Interactive routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet or the phones is guaranteed to be completely secure. It may be possible for third parties not under the control of CPX Interactive to intercept or access transmissions or private communications unlawfully. While CPX Interactive strives to protect users’ personal information, it cannot ensure or warrant the security of any information a user transmits.

How are changes made to the Privacy Policy?

CPX Interactive may find it necessary or be legally obligated to update this Privacy Policy from time to time. When it does update this policy, CPX Interactive will post those changes on this page and update the effective date so that everyone is aware of the information that is collected, how CPX Interactive uses it and under what circumstances CPX Interactive discloses it. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by CPX Interactive prior to the effective date of the policy change. If CPX Interactive makes any material changes, CPX Interactive will notify you by email (sent to the email address specified in your account) or by means of a notice within the Services platform or the corporate website prior to the changes becoming effective. CPX Interactive encourages all users to periodically review this page for the latest information on CPX Interactive’s privacy practices.

What are CPX Interactive’s policies regarding children and SPAM?

The CPX Interactive Services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with CPX Interactive and it does not collect personal information from any person it actually knows is under the age of 18.

Safe Harbor Compliance:


The European Union ("EU") maintains strict privacy laws. These rules differ significantly from U.S. laws. To reconcile these differences, the United States and the EU have created a Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from the EU to the United States. The U.S. and Switzerland have created a similar, but separate Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from Switzerland to the United States. CPX Interactive complies with the U.S. – E.U. Safe Harbor Framework, as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries. CPX Interactive 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 CPX Interactive’s certification, please visit http://export.gov/safeharbor.

Last Updated: May 06, 2016