Privacy Policy

I2 HOLDINGS PRIVACY POLICY

 

Revised: March 30, 2020 

IH2, LLC (formerly I2 Holdings, Inc.) and its associated business unit Predictive Solutions and wholly owned subsidiaries NodeSource and ContexLink (collectively “I2H” or “we”, “us”, “our”) is a technology company that enables our clients to reach consumers with greater efficiency and more relevant messages across various digital channels, including online, mobile, email, and addressable TV.

 

This privacy statement (“Policy”) explains what kinds of information we collect and how I2H strives to collect, use and disclose information in a manner consistent with the laws of the countries in which we do business. This Policy applies to our data platform (“Platform”) and our associated services (“Service(s)”) as well as our websites located at    and  (our “Websites”). We are a data processing company and do not sell data.

 

PRIVACY PRACTICES FOR OUR WEBSITES AND BUSINESS OPERATIONS

Personally Identifiable Information (PII)

I2H collects Personally Identifiable Information (“PII”) from its Websites when you choose to provide it to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, postal address, telephone number, or email address. For example, you may choose to send PII about yourself in an email, or by completing a form on the Websites. I2H uses this information only to contact you to respond to your inquiry.

 

Non-Personally Identifiable Information

I2H also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to the Websites. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. In some places, such as the European Economic Area, certain Non-PII such as cookie IDs and IP addresses are considered personal data.

 

Cookies and other Tracking Technologies

I2H and our partners use cookies or similar technologies to analyze trends, administer the Websites, and track users’ movements around the Websites. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit 

Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising from those partners, click here. Please note you will continue to receive generic ads.

 

Third Party Websites

The I2H Websites may contain links to and advertisements for websites operated by third parties whose privacy practices may differ from I2H policies. While the company endeavors to associate only with reputable entities, I2H cannot guarantee the privacy practices of other websites will reflect ours; we encourage you to check the privacy policies of all websites that you visit.

 

PRIVACY PRACTICES FOR OUR PLATFORM AND SERVICES

 

Overview of I2H’s  connectivity Services

The I2H Connectivity and Context Services include data onboarding, linking, and distribution to companies and many of the players in the digital advertising industry to enable smarter targeting with more relevant messages and more accurate measurement. Onboarding is a service that loads 1st, 2nd and 3rd party data into the digital ecosystem (Customer Data Platform (CDP)), so it can be used for digital advertising purposes. The players include advertisers wishing to reach consumers, advertising supported websites, advertising supported apps, email marketing services, and addressable TV channels.

Today consumers interact with advertisers and brands through a variety of channels – offline and digital. This cross channel interaction is known as “omni channel.” I2H services are used to support these interactions for several types of entities in the digital advertising industry, including: Consumer Brands, Companies that enable the delivery of advertising and marketing messages, and Companies that provide consumer data and insights to brands to help them better understand their current and prospective customers. Brands are interested in understanding consumers anywhere: while online, while watching television, while using their mobile devices and virtually everywhere their customers are making purchasing decisions. All that requires lots of data. And I2H helps brands connect that data in order to help them make intelligent decisions.

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PII and Digital Identifiers uses on the Platform across channels

Due to technical differences across the channels, I2H uses different approaches tailored specifically to each channel to provide our Connectivity Services. The common basis of these services is an ID that I2H assigns to an individual. The ID may be used in a personally identifiable state or in a manner that is not used to identify the individual, depending on the channel and the use.

I2H collects certain types of information in connection with our Connectivity Services. This includes personal data such as name, postal address, email address, and phone number if permitted by our partners and clients through policy notices they have provided to consumers. We also collect other data such as IP address, mobile device ID, and browser and operating system type and version. In addition, we handle, process, and share this data with our marketing platform partners in the course of performing our services; however we do not retain or use this data for our own internal business purposes unless permitted by our clients.

 

I2H Cookie-based Connectivity Services

Connectivity Services for cookie-based integrations are based on a I2H ID and a I2H cookie that together identify a browser. The cookie containing the ID is set when a consumer clicks on a offer, reward, or survey, visits the website of one of our cookie match partners as a registered user, or when a consumer opens certain emails from a cookie match partner. Because match partners know the consumer, they enable I2H to recognize the consumer as well and set the I2H cookie containing the appropriate ID.

For example, our match partners may enable us to place or recognize a cookie on your computer or device, and our match partners may share personal data with us, such as your name, postal address, or email address. I2H uses the personal data to link an ID to information stored in LiveRamp, and add context to the profile. We also may collect information such as the device’s IP address and browser or operating systems type and version. We use this information to recognize consumers and add context across different channels and platforms over time for the purposes of facilitating online advertising, analytics, attribution, fraud detection, and reporting purposes.

For cookie-based integrations, three types of connections are maintained. The first is the connection between I2H cookies and marketing platform partner cookies, a sync that enables I2H to distribute advertising data to partners on behalf of our clients. In this case, the I2H cookies containing I2H IDs are synced with cookies set by our marketing platform partners.

The second connection is between I2H cookies and LiveRamp and/or third-party data providers. In this case, LiveRamp and/or third party data providers onboard their data and I2H matches it to the appropriate I2H IDs, thereby connecting the data to the correct I2H cookie.

Finally, the third connection is between a brand’s data and the I2H graph. When marketers onboard their data, I2H associates the brand’s data with the I2H ID, thus connecting this data to the LiveRamp cookies.

Once all these connections are made, a marketer can use them to understand the context and relationship between their customers to run offers, rewards, surveys, ad's or email marketing campaigns perform and deliver ads or offline marketing to specific individuals when they visit a website with ad inventory. For example, we may facilitate the delivery of an ad to an individual in his or her web browser based on a purchase he or she made in a physical retail store, or we may enable a brand to send a personalized marketing email to that individual based on the fact that he or she visited a particular website.

I2H cookies are set with an RLCDN.com name and expire from I2H’s system after 90 days unless they are renewed or refreshed. Unlike web “tracking” cookies, I2H cookies do not “track” users’ behavior across websites. Instead, I2H cookies are used to recognize an individual so that relevant ads and email marketing can be delivered to the intended recipient.

 

 

I2H Mobile Connectivity Services

Connectivity Services for mobile ID integrations are similar to cookie integrations except they use the mobile advertising ID assigned to the device instead of a cookie – namely the Apple ID for Advertising (IDFA) and the Android Advertising ID (AAID). We associate the I2H ID with the mobile ID just like we would associate the cookie. I2H links marketing platform partners, third party data providers, and data from a brand to mobile devices through the I2H ID.

Mobile advertising IDs do not expire like cookies. Instead the device gives the user the ability to change the ID at any time, thus breaking the connection between the old ID and the device. Consistent with our online policy, I2H IDs are used to recognize individuals so relevant ads and offline marketing can be delivered and campaigns can be measured.

I2H Addressable TV Connectivity Services:

Connectivity Services for addressable TV integrations are similar to online and mobile services except they use the subscriber ID assigned by the carrier to the set-top box instead of a cookie or a mobile ID. We associate the I2H ID with the subscriber ID just like we would associate the cookie or mobile ID. I2H links marketing platform partners, third party data providers, and data from a brand to subscriber IDs through the I2H ID.

Addressable TV subscriber IDs do not expire like cookies. Instead the carrier gives the user the ability to determine if they wish to see targeted advertising on their TV. Consistent with our online and mobile policy, I2H IDs are used only to recognize individuals so relevant ads can be delivered and campaigns can be measured.

 

Pseudonymization Processes:

I2H may recognize an online, mobile or addressable TV user in two ways. First when our match partner shares personal data with us, or second when they share other information with us that is not used to identify individuals. When they share personal data, we can recognize a consumer on an identifiable basis. However, to preserve user privacy, we create a unique I2H ID when we combine it with other anonymous data.

 

I2H values the preservation of consumer privacy, designing its systems and services to treat personal data and other information that is not used to identify individuals with utmost care. I2H chooses the appropriate I2H ID, either personal data or de-identified, based on the services it has been asked to perform; it does not mingle the two in any way that compromises user protections or choice.

 

ADDITIONAL INFORMATION ABOUT OUR PRIVACY PRACTICES

 

Updating and Deleting Your Information

Upon request, and as required under applicable law, I2H will provide you with information about whether we hold any of your data. If you’d like to update, correct, delete, port or deactivate any data that you have provided to the company on the Websites or otherwise via our business operations, please send your request to , and I2H will process your request. We will respond to your request to access within a reasonable timeframe – for data subjects located in the EU, that time frame will be 30 days and I2H will honor such requests as they pertain to personal data.

 

Choice Mechanisms

I2H wants to make sure you are informed of the privacy choices that are available to you. We require that our partners meet the same high standards we have. We contractually require that our match partners employ notice and choice mechanisms, and we work with other information service providers and our partners to assist them in following their respective industry standards. While we only process data as directed by our clients with respect to the Platform and Services, we believe the following information may be helpful.

 

  • Opt-out from Interest Based Advertising from third-party companies - Many of our partners that enable targeted advertising are members of one or more digital advertising industry self-regulatory programs. You may click below for the Network Advertising Initiative (“NAI”), Digital Advertising Alliance (“DAA”) and European Digital Advertising Alliance (“eDAA”) opt-out tools to learn more about targeted or interest-based advertising and to opt out of certain targeting programs.

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  • Mobile Application Choices - Mobile operating systems (e.g., iOS and Android) offer opt-out choice mechanisms applicable to mobile applications and these choice mechanisms may be found via your mobile device settings. Generally when advertising companies are able to detect that a user of a device has opted out via their mobile operating system, such companies won’t use your data to target ads on mobile applications for that device.

 

I2H doesn’t generally engage in the types of behaviors that would subject us to choice requirements via our Platform or Services. However, our clients may engage in such behaviors. As a result, we’ve configured our systems to recognize, manage and store signals from choice mechanisms in multiple channels so that our customers may take action (or refrain from taking action) in response to such signals.  

 

CALIFORNIA DATA SUBJECTS

Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.

 

If you are a customer or partner and have questions about your ability to see the data used to login to our systems, we ask that you direct your question to the person that owns the business relationship. If you are a consumer and want to see what data we may have on behalf of one of our customers, kindly reach out to that individual customer. I2H is contractually prohibited from honoring such requests without specific written instructions from the applicable customer.

You may access those rights with respect to I2H by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email to privacy@interactiveinsights.io. As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days.

The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.

 

We may take reasonable steps to verify your request.  We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.

You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.

 

INDIVIDUALS IN THE EEA

Individuals located in the European Economic Area (“EEA”) are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, an EU (or Swiss) individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their Personal Information, should send us an email at privacy@interactiveinsights.io.

With respect to EU data subjects, Personal Data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.

I2H operates the Platform and provides the Services as a “data processor” under the GDPR. That means I2H only processes data via the Platform and Services as directed by our Clients and for no other purpose. We process certain Personal Data provided by Clients and partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services. We collect contact details from EU data subjects via our Website with consent and ask for consent for our Website to place cookies onto EU desktops. Our sales and marketing team may obtain additional contact details for current and prospective Clients via our legitimate interest so long as they are not overridden by your data protection interests or fundamental rights and freedoms.

 

Privacy Shield

I2H complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. I2H has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit   

 

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, I2H is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

 

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@interactiveinsights.io. If requested to remove data, we will respond within a reasonable timeframe.

 

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@interactiveinsights.io.

 

Onward Transfer of Personal Data

I2H may share data with trusted agents, including PII. These third party agents are prohibited by contract from using the information for purposes other than performing services for I2H. In the EU, such companies are sometimes called “data processors;” in California, they are referred to as “service providers.”  The types of service providers to which we transfer data include: a) cloud computer and data storage providers, b) companies offering tools to send emails and similar communications on our behalf, c) website and b2b sales analytics providers, d) customer relationship management and project management software providers, e) customer billing systems partners, f) outsourced computer programmers helping ensure our systems are operating properly, g) auditing, debugging and security vendors.

 

I2H may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. I2H may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

 

Finally, I2H may transfer information, including any personally identifiable information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If I2H is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a notice on our Websites of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data. In the context of an onward transfer, I2H is responsible for the processing of personal data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. I2H shall remain liable under the Principles if its agent processes such information in a manner inconsistent with the Privacy Shield Principles, unless I2H proves that it is not responsible for the event giving rise to the damage.

 

Data Retention

The data we store on the Platform and utilize as part of our Services is non-sensitive personal data and not subject to any sector specific data retention requirements. We retain data on the Platform as directed by our clients and strongly encourage our clients to retain data only for as long as is reasonably necessary.

 

The data collected via our Websites and our internal business operations is retained for up to 13 months after our last interaction with a particular data subject unless such data is required to be held longer under applicable law.

 

I2H cookies are set with an RLCDN.com name and expire from I2H’s system after 90 days unless they are renewed or refreshed.

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Data Integrity, Purpose Limitation

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use as described above.

 

ENFORCEMENT

 

Privacy Complaints by EU and Swiss Individuals

In compliance with the EU-US Privacy Shield Framework, I2H commits to resolve complaints about your privacy and our collection or use of your personal information. Persons located in the European Union or Switzerland who have inquiries or complaints regarding this privacy policy should first contact us at privacy@interactiveinsights.io.

 

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit  for more information and to file a complaint.

 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at  .

 

Changes To This Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles and other privacy requirements. When we do, we will also revise the “Last Updated” label above. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the information we collect.

 

How to contact I2H

If you wish to contact our privacy team about I2H Connectivity Services, please send an email to  with the word “Privacy Office” in the Subject Line.

 

You may also contact us at:

Privacy Office

IH2, LLC

316 2nd S, Ste 300,

Seattle, WA 98104

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