Privacy Policy

Effective date: September 10, 2024

SECTION A: END USER INFORMATION

THE COLLECTED INFORMATION

As used herein, “Innervate” refers to RevJet, Inc., a Delaware corporation, d/b/a “Innervate”. Innervate creates technologies that permit our customers to personalize, track, and improve internet advertising campaigns (the “Innervate Services”). When our customers use the Innervate Services, they may collect information from the individuals and organizations that may interact with assets owned and controlled by Innervate customers. Such data is subject to the terms of use and policies between the entities using the Innervate Services, and the end user.

This Privacy Policy pertains to the information collected on the Innervate website located at www.Innervate.com (the “Site”) that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include any publicly available information, or de-identified or aggregated consumer information. In particular, over the past 12 months, the Site has collected the following types of information from consumers: user name, email address, content of messages entered into the Site, information submitted by user to the site, browser information, and device information.

Information about your device type (e.g. Apple Desktop, iPhone, Windows Desktop), your operating system type and version, your browser type (e.g. Chrome, Safari) and browser version.
Log information, including the IP address of your device, the website(s) you visited, the start/stop time of each browsing session, your time zone and postal code,
Information about cookies that may be present on your device. Cookies are small files that websites place on your computer as you browse the web. Most web browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some sites may not function properly if you disable cookies.

HOW INNERVATE USES THE COLLECTED INFORMATION

Innervate uses the collected information to track engagement with the Site, to promote Innervate Services, and collect Site user information for marketing, including for the following purposes:

To respond to inquiries regarding Innervate Services.
To provide, support, personalize, and develop our Site, products, and services.
To create, maintain, customize, and secure your account.
To help maintain the safety, security, and integrity of our Site, databases, and business.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Innervate will not collect additional categories of Personal Information from the Site or use the Personal Information collected from the Site for materially different, unrelated, or incompatible purposes without providing you notice.

HOW INNERVATE SHARES THE COLLECTED INFORMATION

Innervate engages service providers to perform functions and provide services to Innervate and the Innervate Customers in the United States and abroad. You agree that Innervate may share the collected Personal Information for legitimate business purposes with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures.

Notwithstanding anything to the contrary in this Privacy Policy, you agree that Innervate may preserve or disclose information if Innervate believes that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the rights or property of Innervate, Innervate Customers, Innervate affiliates, users of our technology, or clients.

Innervate may also share information when Innervate has your consent to do so as set forth in this Agreement.

Innervate may be required to share personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

PRIVACY PRACTICES OF INNERVATE CUSTOMERS

Innervate requires Innervate customers to comply with all applicable laws and regulations regarding our customer’s collection of consumer information using the Innervate Services. Innervate encourages all users to review the privacy policies of sites and apps they visit for information about those sites’ and apps’ data collection and use practices.

Do Not Track and Behavioral Tracking

The Site honors do not track signals and does not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

SECTION B: GENERAL INFORMATION

INFORMATION COLLECTED BY OTHERS

Please be advised that Innervate does not control and is not responsible for the privacy practices of any third party, including, but not limited to, Innervate Customers, Innervate Customers who make use of the Innervate Services, and any website or service that links to or from our website or the Innervate Services. Innervate requires Innervate Customers to comply with applicable law regarding their data collection practices, but Innervate cannot control the actions of Innervate Customers, so please be sure to review the privacy policies of any websites that you may use. This Site may contain links to other sites. Innervate is not responsible for the privacy practices or content of these other sites. When you leave our Site or view a portion of a third party’s site through our Site, Innervate encourages you to read the privacy policies of each such site. This Privacy Policy applies solely to Personal Information collected by Innervate on the Site.

CONFIDENTIALITY AND SECURITY

Innervate has implemented reasonable security measures in order to protect both Personal Information and non-personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

CHANGES TO THIS PRIVACY POLICY

Innervate may amend this privacy policy from time to time. If there are changes to the policy that, in our sole discretion, are material, Innervate will notify you by posting notice of these changes on the Site and in this Privacy Policy.

CHANGES IN CORPORATE STRUCTURE

In the event that Innervate is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets or any other similar transaction, your Personal Information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your Personal Information as transferred to the new entity.

OUR GLOBAL OPERATIONS

Innervate complies with the EU-U.S. Data Privacy Framework(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Innervate has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Innervate has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Innervate commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to BBB National Programs, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information or to file a complaint. The services of BBB National Programs are provided at no cost to you.

Notwithstanding anything in this DPF or the Data Privacy Framework program to the contrary, by accessing this site, you understand and acknowledge that the Court of Justice of the European Union has held that the United States does not afford a level of protection to Personal Information that is essentially equivalent to the protections guaranteed within the European Union. Suppose you are a citizen of the European Union by your access to the Site. In that case, you consent to transfer your Personal Information to the United States and any other country where Innervate and our service providers operate. Privacy and data protection laws in some of these countries may vary from those in the country where you live. You understand and acknowledge that your Personal Information will be processed in the United States and any other country where Innervate and our service providers may operate.

Our organization holds liability in cases of onward transfers to third parties, while our participants remain exempt from such liability. This means that when we share information or data with third parties as part of our operations, we are responsible for ensuring that the transfer is conducted in accordance with applicable laws, regulations, and privacy standards. Our commitment to safeguarding data extends to these onward transfers, and we take all necessary measures to maintain the security, confidentiality, and integrity of the shared information. Our participants, however, are not held personally liable for any issues arising from such transfers, as this responsibility rests solely with our organization.

Fair Information Practices

In order to comply with Fair Information Practices principles articulated by the Federal Trade Commission (https://www.ftc.gov/reports/privacy-online-fair-information-practices-electronic-marketplace-federal-trade- commission) Innervate will notify users of this website who have provided an email address via this website via email within seven business days, should a data breach occur.

Innervate also agrees to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CALIFORNIA RESIDENTS

If you are a resident of the state of California, this section of the Privacy Policy applies to your use of the Site and our use of your Personal Information.

CalOPPA

The California Online Privacy Protection Act (“CalOPPA”) requires a person or company in the United States that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

In compliance with CalOPPA, Innervate agrees that users can visit this website anonymously.

CCPA

Innervate provides you this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized terms use in this section that are not otherwise defined in this agreement have the meaning set forth in the CCPA.

Transparency

What Innervate collects. Innervate collects Personal Information as described in the “Collected Information” section of this Privacy Policy.

How Innervate uses the collected Personal Information. You have the right to know how Innervate obtains your Personal Information, how it is used, and what the business reasons are for such use. This is also described in the “Collected Information” section of this Privacy Policy.

Sharing of Personal Information. You have the right to know if your Personal Information is shared with any third parties. Innervate shares Personal Information with Service Providers to perform services specified in a contract. Innervate also shares Personal Information with other third parties as described in the “Sharing of Personal Information” section of the Privacy Policy.

Sale of your Personal Information. You have the right to know whether your Personal Information is sold. Personal Information is sold when it is shared with a third party for value, for a purpose other than a Business Purpose. Innervate does not sell your Personal Information.

Control

You have the rights to: 1) know what Personal Information of yours Innervate has collected and retained over the past 12 months via the Site; 2) receive a copy of your Personal Information that Innervate has retained; 3) request our deletion of your Personal Information. Once Innervate receives a request from you regarding to any of these rights, Innervate will work with you to confirm your identity, and comply with your request. Your request may be denied if there is an exception under the CCPA that permits retention of your Personal Information, such as complying with a legal obligation, fulfilling an obligation to you as our customer, or protecting against malicious or illegal activity. Innervate does not sell your Personal Information, so Innervate does not offer you an option to opt out of the sale of your data.

Exercising your rights

To exercise your rights described in the “Control” section, please submit a request by either calling at (650) 508-2213 or emailing Innervate at all.dataprotection@Innervate.com, or by following the instructions in any of our promotional emails.

Benefits of Our Use of Personal Information

The CCPA permits offering of financial incentives to provide your Personal Information via the Site, such as rewards programs, or premium services. If Innervate offers any such incentives on the Site, your participation is optional. If you chose to participate in any such program offered via the Site, your participation will be subject to any applicable terms of use, and you may withdraw at any time. The CCPA prohibits discriminating against you for exercising your rights. Examples of discrimination include denying you goods or services, providing a different price, or providing you a different quality of service. Business are permitted to provide different levels of quality or prices if the differences are reasonably related to the value of your Personal Information. This section applies only to Personal Information collected via the Site.

CONTACT INNERVATE

If you have questions about this policy, or inquiries or requests regarding your Personal Information, please contact Innervate at all.dataprotection@Innervate.com. You have the right to request access to, and correction or deletion of, any of your Personal Information in the possession of Innervate, and to prohibit or request restriction of Innervate’s storage or processing of such Personal Information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want the data to be deleted; (iii) Innervate no longer needs the Personal Information for the relevant purposes, but use is required it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to the Personal Information use based on legitimate interests verification as to whether there is a compelling interest to continue to use your data.

Innervate can continue to use your Personal Information following a request for restriction, where:

Innervate has your consent; or
to establish, exercise or defend legal claims; or
to protect the rights of another natural or legal person.

You have the right at any time to withdraw your consent to Innervate’s processing of such Personal Information, without affecting the lawfulness of Innervate’s processing based on your consent before the time of withdrawal. You also have the right to request that Innervate delete your Personal Information. Innervate is not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

In your message requesting the review, correction or deletion of your Personal Information, or a restriction on processing your Personal Information, please indicate the right you would like to exercise and the Personal Information that you would like to access, review, correct, or delete.

Innervate may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. Innervate reserves the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Innervate may not always be able to fully address your request, for example if it would impact the duty of confidentiality owed to others, or if Innervate is legally entitled to deal with the request in a different way.

For DPF inquiries, please include “DPF” in the subject of your message.

LINKS TO PARTNER PRIVACY POLICIES

The IP geolocation data is provided by https://www.ip2location.com"

"This site or product includes IP2Location™ Country Multilingual Database, which is available from https://www.ip2location.com"

The Innervate Services make use of the YouTube API Services. By using the Innervate Services, you are also agreeing to be bound by the YouTube Terms of Service, which can be found here: https://www.youtube.com/t/terms

Some of our partners may choose to run Innervate using their own domains. For your convenience you may find their privacy policies as links below:

List of subprocessors

TCF Attestation