We provide digital products, including, but not limited to, Spearmint and Peppermint (“Products”). Third parties (which may include advertisers, advertising agencies, marketers, researchers, telecommunications companies, technology providers and other entities) license our Products (“Customers”) and employ our Products in connection with websites, mobile applications, advertisements and/or related services (“Customer Websites”) to collect and process data on consumers, including use and/or access to or visiting of Customer Websites (“Consumers”). Customers typically use our Products to collect data to better customize marketing, advertising, analytics and research efforts, including but not limited to, target advertising, measurement insights, market research and analytics, analyzing device information, and other types of Customer Website customization. As Consumers browse the Internet through their Devices, we collect information on or related to Consumers and their Devices. Our Products connect Consumers through devices and other identifiers, including, but not limited to, smartphones, personal computers, tablets, smart televisions and other smart devices (“Devices”) as further detailed on our website https://www.mintmeasure.com (the “Website”).
In order to access and use the Services as a Customer, you must agree to our Product Terms of Service at https://www.mintmeasure.com/terms-of-service (the “Terms”). The Terms only apply to Customers (i.e., and not Consumers).
Collection and Use of Information Through Our Website
Consumer- and Customer-Provided Information: When you visit our Website, we may collect certain types of information about you that you submit voluntarily. This information is “Personal Information” since it identifies you, and may include your name, address, email address, and telephone number. This may occur when you send us an email, submit a website form requesting information about Mint Measure or our Services, use an on-site live chat service, or otherwise communicate with us. Our legal basis for processing this information is your consent, the performance of a contract between you and us, and our legitimate interests, namely the proper administration of our Website and communications with you.
Registration and Billing Information: When Customers ortheir representatives access the Website or, we may process information aboutyou that was provided by you when you registered, for example, the Customer’sname, email address, and password (“Registration Information”). We alsocollect certain information from representatives accessing the Services onbehalf of a Customer, including credit card numbers and associated billinginformation (“Billing Information”) in order to process subscriptions.
Automatically-Collected Information: Whether you are a Consumervisiting our Website or acting on behalf of a Customer as part of theregistration process, we may receive additional information about you that iscollected automatically. This additional information may include Internetprotocol (IP) address, domain names, browser, device type, access times, latitudeand longitude location information, the web pages you view, and other trackeduser actions. This information may also include Cookies (defined below), webbugs, device information, and navigational data like Uniform Resource Locators(URLs), which we may use to gather information regarding the date and time ofyour visit, as well as your geo-location (from your IP address). “Cookies”are small pieces of information that a website sends to your browser.
How We Use Information We Collect Through Our Website: We use informationthat we collect through our Website to respond to your requests, resolveproblems, improve the quality of the Website and Services, and market ourproducts or services and those of third parties to you. We may also anonymizePersonal Information by removing identifying characteristics and aggregating itwith the information of others so that it no longer constitutes “PersonalInformation”. We may use such information to create compilations of aggregateddata and/or statistics and reports, and any other uses without restriction. Wemay use information we collect through our Website to comply with our legal andregulatory obligations, policies and procedures, and for internaladministrative purposes.
Collection and Use of Information Through the Service
Customer-Provided Information From Customer Websites: When Consumers visitour Customer Websites, we may process information about you that is provided tous by our Customers. This additional information may include your domain names,browser, operating system information, device type, mobile advertisement IDs(e.g., associated with app usage), access times, the web pages you view, browsinghistory, search history, information on a Consumer’s interaction with a CustomerWebsite and advertisements, and other tracked user actions. This informationmay also include Cookies, web bugs, device information, and navigational datalike Uniform Resource Locators (URLs) to gather information regarding the dateand time of your visit, as well as your geo-location (from your IP address). Wecollect and enable our Customers to collect information in a web browser, includingusing code from our Products (as employed by a Customer Website) to send datato servers and/or store data on a computer (“Pixels”). We also exchangedata in batch files with our third party affiliates. In connection withConsumers and Customer Websites, we do not use, collect or permit our Customersto send to us: (i) any information that can directly identify (or bere-identified with) a natural person or household; (ii) any names, InternetProtocol address, email address, or other similar identifiers; and (iii) anyPersonal Information.
How We Use Information We Collect Through the Service: We use informationthat we collect through the Service to provide our Services to our Customers;respond to your requests, resolve problems, improve the quality of theServices, and market our products or services and those of third parties toyou. We will use Registration Information from our Customers only for purposesof authentication, and we will use Billing Information from our Customers onlyto process Customer payments. We may also anonymize such information byremoving identifying characteristics (if any) and aggregating it with theinformation of others. We may use such information to create compilations ofaggregated data and/or statistics and reports, and any other uses withoutrestriction. We may use information we collect through the Service to complywith our legal and regulatory obligations, policies and procedures, and forinternal administrative purposes.
(Disclosing Personal Information to ThirdParties)
Mint Measure does not request or knowingly receive orcollect Sensitive Personal Information. Nonetheless, if at any point in thefuture Mint Measure receives or collects Sensitive Personal Information aboutyou, Mint Measure will not process such information about you for purposesother than those for which the information was originally obtained orsubsequently authorized by you unless you explicitly consent to the processing,or as required or permitted, or where not prohibited by law or regulation. “SensitivePersonal Information” means Personal Information that reveals race, ethnicorigin, political opinion, religious or philosophical beliefs, trade unionmembership, genetic data, biometric data where processed to uniquely identify aperson, any information that concerns medical or health conditions or sex life,or information relating to the commission of a criminal offense.
Opting Out of Collecting Information About Youon Customer Websites (For Consumers to Customer Websites)
When Consumers visit our Customer Websites, we mayprocess information about you that is provided to us by our Customers. If youprefer that we do not process information about you on Customer Websitesprovided to us by our Customers, please contact us at: firstname.lastname@example.org
Please note that this opt-out link sets a “session”cookie (also called a “first-party cookie”) to exclude you from our Products.
Youmay also opt-out of Mint Measure and other entity’s data collection practices thoughthe Network Advertising Initiative (“NAI”) opt-out page https://optout.networkadvertising.org/?c=1, or Digital Advertising Alliance’s(“DAA”) opt-out page https://optout.aboutads.info/?c=2&lang=EN
Opting Out of Marketing Communications
If you receive marketing or promotional emails from us,you may unsubscribe at any time by following the instructions contained withinthe email or by sending an email to the address provided in the “Contact Us”section.
We follow generally accepted industry standards toprotect the information submitted to us, both during transmission and once wereceive it. Taking into account the risks involved in the processing and thenature of the Personal Information we process, Mint Measure maintainsadministrative, technical, and physical safeguards to protect information inour possession against accidental or unlawful destruction, accidental loss,unauthorized alteration, unauthorized disclosure or access, misuse, and anyother unlawful form of processing. This includes, for example, firewalls,password protection, encryption, and other access and authentication controls.
However, no method of transmission over the Internet, ormethod of electronic storage, is 100% secure. We cannot ensure or warrant thesecurity of any information you transmit to us or store on the Service, and youdo so at your own risk. We also cannot guarantee that such information may notbe accessed, disclosed, altered, or destroyed by breach of any of our physical,technical, or managerial safeguards.
ACCESSING AND CONTROLLING YOUR INFORMATION
Data protection laws (notably, the CCPA) make adistinction between organizations that process Personal Information for theirown purposes (known as “businesses” (under the CCPA)) and organizations thatprocess personal data on behalf of other organizations (known as “serviceproviders” (under the CCPA)). If you have a question or complaint about howyour Personal Information is handled, these should always be directed to therelevant business, since the business has primary responsibility for yourPersonal Information.
For Consumers to Customer Websites: When Mint Measure actsas a provider of Services to its Customers on Customer Websites, we do not use,collect or permit our Customers to send to us Personal Information aboutConsumers. We have no direct relationship with Consumers on Customer Websites,and any such Consumers who seek access, or who seek to correct, amend, ordelete their Personal Information should direct their inquiries to the relevantCustomer.
USE OF THIRD PARTY AFFILIATES
Mint Measure may also use third parties for purposes oflinking existing Consumers or otherwise known IDs (“Matching IDs”). MatchingIDs may represent device IDs, cookie IDs, customer IDs, or other types of datameaningful to Mint Measure, and is recognized only as another pseudonym in MintMeasure’s systems. Mint Measure requires that such third parties obscure andprotect all Matching IDs before sending them to Mint Measure, such that theunderlying data is either meaningless to Mint Measure or is encrypted such thatMint Measure has no ability to access the underlying data.
Mint Measure also uses Qubole in connection withdata transformations, and data we collect on Consumers is in this tool;provided, no such data constitutes Personal Information.
The Website may contain links to other websites that arenot owned or controlled by us. When you click on such a link, you will leaveour Website and go to another site. During this process, another entity maycollect Personal Information from you. We have no control over, do not review,and are not responsible for the privacy policies of or content displayed onsuch other websites.
Our Services are not directed at nor intended for use byindividuals under 16, and we require our Customers to put necessary filters inplace to not transmit this type of data to us. Moreover, we do not target tocollect data from children under the age of sixteen (16), and we do notknowingly collect Personal Information from individuals under 16. If you are under the age of 16, please do notattempt to register with the Services or send any information about yourself tous, including your name or e-mail address. If you learn that a child under 16has provided us with Personal Information, please contact us. If we becomeaware that a child under 16 has provided us with his or her PersonalInformation, we will promptly delete such data.
Data Retention and Destruction
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (CCPA)
Information We Collect (CCPA)
Category and Examples
Collected on the Website?
Collected on our Products (from Customer Websites)?
A real name, Internet Protocol address, email address, or other similar identifiers.
B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C: Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data
Physical location or movements.
H. Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.
To summarize the above, we collect Personal Informationabout Consumers to our Website, and we do not collect Personal Informationabout Consumers on Customer Websites, as further described in the PrivacyPolicy.With respect to Categories F, G and K in the table aboveregarding our Products and Customer Websites, Mint Measure does aggregateinformation from large groups of visitors, in an anonymous and de-identifiedway, and these aggregations may rely on algorithmic inferences drawn from informationcollected on those Websites, as listed in other categories above. We use suchinformation to create compilations of aggregated data and/or statistics andreports.Note that “Personal Information” does not include:
Publicly available information from government records.
De-identified or aggregated consumerinformation.
Information excluded from the CCPA’s scope, including:
- Health or medical information covered by theHealth Insurance Portability and Accountability Act of 1996 (HIPAA) and theCalifornia Confidentiality of Medical Information Act (CMIA) or clinical trialdata;
- Personal Informationcovered by certain sector-specific privacy laws, including the Fair CreditReporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California FinancialInformation Privacy Act (FIPA), and the Driver’s Privacy Protection Act of1994.
We obtain the categories of Personal Information listedabove from the following categories of sources:
Directly from our Customers or their agents. Forexample, from documents that our Customers provide to us related to the Servicefor which they engage us.
Indirectly from our Customers or their agents through their use of our Service.
Directly and indirectly from activity on our Website ora Customer Website.
Use of Personal Information (CCPA)
We may use or disclose the Personal Information wecollect for one or more of the following business purposes:
To fulfill or meet the reason for which the informationis provided.
To provide you with information, products or servicesthat you request from us.
To provide Customers with information regarding you and productsor services of Customer.
To provide you with email alerts, event registrationsand other notices concerning our products or services, or events or news, thatmay be of interest to you.
To carry out our obligations and enforce our rightsarising from any contracts entered into between you and us, including forbilling and collections.
To improve our Website and present their contents toyou.
For testing, research, analysis and product development.
As necessary or appropriate to protect therights, property or safety of us, our Customers or others.
To respond to law enforcement requests and as requiredby applicable law, court order, or governmental regulations.
As described to you when collecting yourPersonal Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture,restructuring, reorganization, dissolution, or other sale or transfer of someor all of our or a Customer’s assets, whether as a going concern or as part ofbankruptcy, liquidation, or similar proceeding, in which Personal Informationheld by us or a Customer is among the assets transferred.
We will not collect additional categories ofPersonal Information or use the Personal Information we collected formaterially different, unrelated, or incompatible purposes without updating thisnotice.
Sharing Personal Information (CCPA)
We may disclose your Personal Information to a thirdparty for a business purpose. When we disclose Personal Information for abusiness purpose, we enter a contract that describes the purpose and requiresthe recipient to both keep that Personal Information confidential and not useit for any purpose except performing the contract.In the preceding twelve (12) months, we have disclosedthe following categories of Personal Information for a business purpose: None.
We disclose your Personal Information for a businesspurpose to the following categories of third parties:
Third parties to whom you or your agents authorize us todisclose your Personal Information in connection with products or services weprovide to you.
In the preceding twelve (12) months, we have not sold any Personal Information.
Your Rights and Choices (CCPA)
The CCPA provides California residents withspecific rights regarding their Personal Information. This section describesyour CCPA rights and explains how to exercise those rights.
Access to Specific Information and DataPortability Rights (CCPA)
You have the right to request that we disclose certaininformation to you about our collection and use of your Personal Informationover the past 12 months. Once we receive and verify your request, we willdisclose to you:
The categories of Personal Information wecollected about you.
The categories of sources for the PersonalInformation we collected about you.
Our business or commercial purpose forcollecting or selling that Personal Information.
The categories of third parties with whom weshare that Personal Information.
The specific pieces of Personal Information wecollected about you (also called a data portability request).
(Applicable if we sell or disclose your PersonalInformation for a business purpose) Two separate lists disclosing:
- Sales, identifying the Personal Informationcategories that each category of recipient purchased; and
- Disclosures for a business purpose, identifyingthe Personal Information categories that each category of recipient obtained.
Deletion Request Rights (CCPA)
You have the right to request that we delete any of yourPersonal Information that we collected from you and retained, subject tocertain exceptions. Once we receive and confirm your verifiable consumer request,we will delete (and direct our service providers to delete) your PersonalInformation from our records, unless an exception applies.Wemay deny your deletion request if retaining the information is necessary for usor our service providers to:
Complete the transaction for which we collectedthe Personal Information, provide a good or service that you requested, takeactions reasonably anticipated within the context of our ongoing businessrelationship with you, or otherwise perform our contract with you.
Detect security incidents, protect againstmalicious, deceptive, fraudulent, or illegal activity, or prosecute thoseresponsible for such activities.
Debug products to identify and repair errorsthat 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 ElectronicCommunications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific,historical, or statistical research in the public interest that adheres to allother applicable ethics and privacy laws, when the information’s deletion maylikely render impossible or seriously impair the research’s achievement, if youpreviously provided informed consent.
Enable solely internal uses that are reasonably alignedwith consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of thatinformation that are compatible with the context in which you provided it.
Exercising Access, Data Portability, andDeletion Rights (CCPA)
To exercise the access, data portability, anddeletion rights described above, please submit a verifiable consumer request tous by:
Contacting us via: email@example.com
Only you or a person registered with the CaliforniaSecretary of State that you authorize to act on your behalf,
may make averifiable consumer request related to your Personal Information. You may alsomake a verifiable consumer
request on behalf of your minor child.
You may only make a verifiable consumer request foraccess or data portability twice within a 12-month period. The verifiableconsumer request must:
Provide sufficient information that allows us toreasonably verify you are the person about whom we collected PersonalInformation or an authorized representative.
Describe your request with sufficient detailthat allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or
authority to make the
request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format (CCPA)
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goodsor services, including through granting discounts or other benefits, orimposing penalties.
Provide you a different level or quality ofgoods or services. Suggest that you may receive a different price or rate forgoods or services or a different level or quality of goods or services.
Changes to This Privacy Notice (CCPA)
We may revise this privacy notice from time to time in our sole and absolute discretion. If we decide to change our privacy notice, we will post the revised statement on our Website. If changes are significant and materially affect your rights under this privacy notice, we may provide a more prominent notice on our Website or Services. As we may make changes at any time without notifying you, we suggest that you periodically consult this privacy notice. Please note that our rights to use any information collected will be based on the privacy notice in effect at the time the information is used.
Contact Information (CCPA)
If you have any questions, comments or concernsabout the privacy notice or would like to request additional informationregarding our privacy practices, please contact us at:
Contacting us via: firstname.lastname@example.org