Latest revision: April 14, 2020
Mobile Direct Response, LLC dba #250 (“Company” or “We” or “Us” or “Our”) respects your privacy and is committed to protecting it through our compliance with this policy.
We want you to understand how we handle the personal information about you that we may obtain and the high standards we employ to safeguard this information. This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.pound250.com (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On the Website.
- In email, text, and other electronic messages between you and the Website.
- When you dial #250 on your mobile phone
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), and/or through any application or content (including advertising) that may link to or be accessible from or on the Website.
Information We Collect
The information we may collect through the Website includes:
- Personally identifiable information (“personal information”), including, but not limited to: your name, email address, telephone number, and other information.
- Other information (“other information”), about your company and state of business, internet connection, the equipment you use to access the Website, and usage details, including IP address, browser type, operating system, access times, areas of the Website you viewed, what content you viewed on the Website, and the pages you viewed directly before and after accessing the Website.
- Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad;
- Information Collected from E-mail
You may volunteer to provide us personally identifying information, for example your mailing address, in an electronic message or web-based form. Information collected in this manner is used solely for responding to your request unless noted in the specific web page where your request is made. We do not share this information with government agencies, commercial and non-commercial entities, or the public unless noted on a particular web page.
We collect information:
- When you provide it to us.
- Automatically as you navigate the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us
We collect information you provide directly to us, for example, when you participate in interactive features of the Website (such as online chat), fill out a form, subscribe to email updates or a newsletter, respond to a survey, request customer support, or otherwise communicate with us via the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to the Website, including traffic data, page view history, logs, and other communication data related to the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is summary data that is only statistical and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Website.
We use various technologies to collect information, including sending cookies to your computer or mobile device and placing web beacons on pages of the Website.
- Specifically, the AdRoll cookie served through the AdRoll platform for this purpose is named “__adroll”. AdRoll may also drop an additional AdRoll opt-out cookie if you opt-out as described below.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
Information We Collect from Third Parties
Some of our features rely on information about you that we collect from third parties, such as our advertising platform, AdRoll. We may also work with different third-party partners to supplement information we may automatically collect from you or that you provide. For example, our partners may provide us with information such as your estimated primary media market, so that we can give you more personalized recommendations.
How We Use Your Information
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Website to:
- Provide you with our services and any other information, products, or services that you request from us.
- Allow you to participate in interactive features on the Website.
- Present the Website and its contents to you.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- Send you technical notices, updates, security alerts, and support and administrative messages.
- Increase the efficiency and operation of the Website.
- Monitor and analyze usage and trends to improve your experience with the Website.
- Notify you of updates to the Website.
- Offer new products, services, and/or recommendations to you.
- Perform other business activities as needed.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Request feedback and contact you about your use of the Website.
- Resolve disputes and troubleshoot problems.
- Respond to product and customer service requests.
- Provide, maintain, and improve the Website.
- Link or combine with information we get from others to help understand your needs and provide you with better service.
- Fulfill any other purpose for which you provided the information.
- For any other purpose with your consent.
We may also use information to contact you about our own goods and/or services that may be of interest to you. If you do not want us to use your information in this way, please contact us to opt-out (see Contact Information). For more information, see Choices About How We Use and Disclose Your Information.
Disclosure of Your Information
We do not rent, sell, or share personal or financial Information except and only under the specific provisions specified below. We do not share your personal or financial information with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission. We may share aggregate or de-identified data, or other information, with third parties for any purpose.
We may share information, including personal information, as follows:
- With your permission. We may share the information we receive with third parties when we have your permission or at your direction.
- With our vendors and service providers. We may share any information we receive with vendors and service providers retained to help us provide or improve the services or the Website.
- As required by law and similar disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; defend against legal claims; respond to your requests; protect the rights, property, and safety of you, Company, or others; or as otherwise required by law.
- In connection with a merger, sale, or other asset transfer. If we are involved in a merger, acquisition, financing, reorganization, or other substantial corporate transaction, or in the unlikely event of bankruptcy, any information we possess, including personal information, may be shared, sold, or transferred as part of such a transaction as permitted by law and/or contract. In such cases, we cannot control how other entities may use or disclose such information.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated or non-agent third parties for promotional purposes.
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions. This opt out also does not apply to communications that are required by law.
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
- You can opt-out of receiving targeted ads from us. Our advertising platform, AdRoll, is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from #250, AdRoll, and from other NAI approved member companies.
- We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
- We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices
Please note that when using the ad industry opt-out tools described above:
- If you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.
- If you use multiple browsers or devices you may need to execute this opt out on each browser or device.
- Other ad companies’ opt-outs may function differently than our opt-out.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may contact us to submit a request (see Contact Information). However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Accessing and Correcting Your Information
We offer you a number of ways to control collection and use of your information when you use the Website. Your options include:
Request for personal information disclosure
You can request for us to disclose certain information about our collection and use of your personal information over the past 12 months. You may contact us to request disclosure of the following information:
- Categories of personal information we collected about you
- Categories of sources from which the personal information we collected about you were collected
- Our business purpose for collecting that personal information
- Categories of third parties with whom we have shared that personal information
- The specific pieces of personal information we collected about you
Request for personal information deletion
You can request for us to delete any personal information we have collected from you, subject to certain exceptions. Your request may be denied if the information is necessary for us or our service provider(s) to:
- Complete the transaction for which the personal information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or our service provider(s), or otherwise perform our contract with you or our service provider(s).
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
- Debug systems to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Submitting a request
To exercise your access, portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing firstname.lastname@example.org or calling 1-888-421-4007.
California residents may have additional information rights and choices. Please see Your California Privacy Rights for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from our systems.
Third-Party Websites and Applications
Controls for Do-Not-Track Features
In compliance with the European Union (“EU”) General Data Protection Regulation (“GDPR”), we may rely upon one or more legal bases defined in the GDPR to collect, use, share and otherwise process the personal information of individuals located in the EU, including where:
- Necessary to perform a contract we have with you, such as our terms of engagement, and to provide the services;
- You have consented to the processing (in which case you may revoke your consent at any time);
- Necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
- Necessary to protect your vital interests or those of others;
- Necessary in the public interest; and
- Necessary for the purposes of our or a third party’s legitimate interests, such as those of clients, partners, staff or others, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
Where we collect, use, disclose and otherwise process your information based on legitimate interests, we may rely on the following interests:
- Provision of services: We use your information to provide services to you and others.
- Keeping our services safe and secure: We use your information in certain instances as necessary to pursue our and your legitimate interests of keeping some of our services, such as our domains, websites, offices and events, safe and secure. For example, we collect IP addresses to ensure our website are not subject to fraudulent access.
- Marketing our services: We use your information as necessary to pursue our legitimate interests in marketing our services.
- Providing, improving and developing services: We use your information as necessary to pursue our legitimate interests in tailoring and improving our services. For example, if you are a customer, we may send you a survey or questionnaire to understand your experience in obtaining services from us.
- Providing seamless services with our affiliates: In some cases, the services require the engagement of, or sharing of your information with, other companies affiliated with us.
If you are located in the EU, under certain circumstances, you may have certain legal rights under the GDPR, including:
- To access the personal data we maintain about you
- To receive information about how we process your personal data
- To correct your personal data
- To have your personal data erased
- To object to or restrict how we process your personal data
- To request your personal data be transferred to a third party
- To withdraw any consent you may have given us to process your personal data
If you are an EU resident, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below. If you are located in the EU and you believe that we have infringed your rights under the GDPR, please contact us (see Contact Information).
You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.
We will retain your information for as long as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, prevent fraud or abuse, resolve disputes, enforce our agreements, or take other actions permitted by law. Anonymous or aggregated information that does not identify you personally may be retained indefinitely.
Protection of Information and Security
We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All site access requests will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to the Website. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
For site security purposes, and to ensure that this service remains available to all users, all network traffic is monitored in order to identify unauthorized attempts to upload or change information, or otherwise cause damage or conduct criminal activity. Unauthorized attempts to defeat or circumvent security features, to use the system for other than intended purposes, to deny service to authorized users, to access, obtain, alter, damage, or destroy information, or otherwise to interfere with the system or its operation are prohibited. Evidence of such acts may be disclosed to law enforcement authorities and result in criminal prosecution under the Computer Fraud and Abuse Act of 1986 (Pub. L. 99-474) and the National Information Infrastructure Protection Act of 1996 (Pub.L. 104-294), (18 U.S.C. 1030), or other applicable criminal laws. Anyone using or accessing this system expressly consents to such monitoring.
Children Under the Age of 13
The Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website or through any of its features, use any of the interactive features of the Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us (see Contact Information).
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
Where client access is required, the use of a User ID and password will be used to authenticate to our systems. You are responsible for keeping your User ID and password confidential. You should promptly notify us if you become aware or suspicious of unauthorized use of your User ID and password.
Disclaimer for Hypertext Links
Disclaimer of Information
All information provided by us on this web site is made available to provide immediate access for the convenience of interested persons. While we believe the information to be reliable, human or mechanical error remains a possibility. Therefore, we do not guarantee the accuracy, completeness, timeliness, or correct sequencing of the information. Neither we, nor any of the sources of the information, shall be responsible for any error or omission, or for the use of, or the results obtained from the use of, this information.
Disclaimer of Endorsement
Reference herein to any specific commercial products, processes, or services by trade name, trademark, manufacturer, or otherwise, does not constitute or imply its endorsement, recommendation, or favoring by us.
Certain trademarks, trade names, images, logos, design, text, graphics and pictures on this web site are proprietary to us. They may NOT be copied, reproduced, republished, posted, transmitted or distributed in any way. The use of any such material for any other reason, on any other web site, or the modification, distribution or republication of this material without prior written permission from us is strictly prohibited. Except as may be expressly provided, nothing contained herein shall be construed as conferring any license, software or right under copyright or other intellectual property rights.