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    Privacy Policy - Brand Campaigns

    Effective date: 02/01/2024

    Aisle is in the business of helping brands connect with people. This Privacy Policy governs how we process personal data and send text messages on our brand customers’ (“Brand”) behalf to the Brand’s users. In the ordinary course of providing these services we necessarily process personal data and send text messages to Brands’ users on the Brand’s behalf in furtherance of their campaigns. In doing so we act as a service provider and we follow the Brand’s instructions. We do not sell, share, or otherwise process the personal data of Brands’ users, including their SMS Opt-In, for any reason other than to provide the Brand with Aisle’s services. This Privacy Policy does not cover the practices of Brands or companies we don’t own or control or people we don’t manage. To see how we process personal data of Aisle Audience users and website visitors, please visit Aisle’s [HERE].

    You may print a copy of this Privacy Policy by clicking the "Print" button in the top right corner of the page.

    As we continually work to improve, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Aisle website or by some other means. If you use Aisle after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Please note that if the Brand on whose behalf Aisle processes your personal data is required to provide a notice regarding their privacy practices to you, this obligation is the responsibility of the Brand to provide such notice.

    Privacy Policy Table of Contents

    • What this Privacy Policy Covers
    • Personal Data
      • Categories of Personal Data We Collect
      • Our Commercial or Business Purposes for Collecting Personal Data
      • Other Permitted Purposes for Processing Personal Data
      • Categories of Sources of Personal Data
    • How We Disclose Your Personal Data
    • Data Security
    • Personal Data of Children
    • State Law Privacy Rights
    • Contact Information

    What This Privacy Policy Covers

    This Privacy Policy covers how we treat Personal Data that we gather as a service provider when you interact one of our Brand customers. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.

    Personal Data

    Categories of Personal Data We Collect

    This chart details the categories of Personal Data that we may collect on behalf of a Brand when providing Aisle services to that Brand. Note that the actual Personal Data collected will depend on the nature of the individual relationship and the specific services provided to the Brand on whose behalf Aisle processes your Personal Data. Brands have their own policies regarding the collection, use, and disclosure of the personal data of their end users. If you are an end user of one of our Brand customers and want to learn about how that Brand handles your Personal Data, we encourage you to read the Brand’s privacy policy.

    Aisle’s processing of the Personal Data included here is performed in a service provider function in which we follow the Brand’s instructions. We do not sell, share, or otherwise process the Personal Data of Brands’ users, including their SMS Opt-In, for any reason other than to provide the Brand with Aisle’s services.

    Category of Personal Data (and Examples)Business or Commercial Purpose(s) for CollectionCategories of Third Parties With Whom We Disclose this Personal Data
    Profile or Contact Data such as first and last name, email, phone number, unique identifiers, and your SMS Opt-In.
    • Providing, Customizing and Improving the services we provide to Brands
    • Corresponding with you on our Brand’s behalf
    • Service Providers
    • Business Partners (i.e., Brands)
    Payment Data such as financial account information, payment card type, last 4 digits of payment card, and billing address, phone number, and email.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers (specifically our payment processing partner, PayPal, Inc. (which includes Venmo))
    • Business Partners (i.e., Brands)
    Commercial Data such as purchase history and consumer profiles.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Device/IP Data such as IP address, device ID, domain server, and type of device/ operating system/ browser used to access the services we provide to Brands.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Web Analytics such as web page interactions, referring webpage/source through which you accessed the services we provide to Brands, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the services we provide to Brands.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Social Network Data such as email, phone number, user name, IP address, and device ID.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Consumer Demographic Data such as age and/or date of birth, zip code, gender, race, ethnicity, and sex life or sexual orientation.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Geolocation Data such as IP-address-based location information, and GPS data.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Sensory Data such as photos, videos, or recordings of you and/or of your environment.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Categories of Data Considered “Sensitive” Under the State Privacy Laws (as defined below) limited to precise geolocation data, and only when you opt-in.
    • Providing, Customizing and Improving the services we provide to Brands

    We do not collect Sensitive Personal Data for the purpose of inferring characteristics about you.

    • Service Providers
    • Business Partners (i.e., Brands)
    Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
    • Providing, Customizing and Improving the services we provide to Brands
    • Service Providers
    • Business Partners (i.e., Brands)
    Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, or other communications you send us.
    • Providing, Customizing and Improving the services we provide to Brands
    • Corresponding with You
    • Service Providers
    • Business Partners (i.e., Brands)

    Our Commercial or Business Purposes for Collecting Personal Data

    Aisle collects and processes your Personal Data to provide services to our Brand customer, which include send text messages to Brands’ users on the Brand’s behalf in furtherance of their campaigns. Our processing of your Personal Data is therefore governed by the agreement in place between Aisle and the Brand. In this capacity Aisle acts as a service provider and we follow the Brand’s instructions. We do not sell, share, or otherwise process the personal data of Brands’ users, including their SMS Opt-In, for any reason other than to provide the Brand with Aisle’s services.

    Other Permitted Purposes for Processing Personal Data

    In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Aisle or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

    Categories of Sources of Personal Data

    • You
      • When you provide such information directly to us.
        • When you create an account or use our interactive tools and services.
        • When you voluntarily provide information in free-form text boxes through the services we provide to Brands or through responses to surveys or questionnaires.
        • When you send us an email or otherwise contact us.
    • Third Parties
      • Business Partners
        • Brands provide us with Personal Data about you in order to facilitate their campaigns.
      • Vendors
        • We may use analytics providers to analyze how you interact and engage with the services we provide to Brands, or third parties may help us provide you with customer support.
      • Advertising Partners
        • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with the services we provide to Brands.
      • Third-Party Credentials
        • If you provide your third-party account credentials, such as your social network account credentials, to us or otherwise sign in to the services we provide to Brands, some content and/or information in those accounts may be transmitted into your account.

    How We Disclose Your Personal Data

    We disclose your Personal Data to the categories of service providers and other parties listed in this section.

    • Service Providers. These parties help us provide the services to our Brand customers or perform business functions on our behalf. They include:
      • Hosting, technology and communication providers.
      • Security and fraud prevention consultants.
      • Support and customer service vendors.
      • Product fulfillment and delivery providers.
      • Payment processors.
        • Our payment processing partner Venmo (offered by PayPal, Inc.) collects your voluntarily-provided payment card information necessary to process your payment.
        • Please see Stripe’s, Square’s, or Braintree’s terms of service and privacy policy for information on its use and storage of your Personal Data.
    • Analytics Partners. These parties provide analytics on web traffic or usage of the services and help us provide the services to our Brand customers. They include:
      • Companies that track how users interact with the services.
    • Business Partners. We share your Personal Data with the Brand on whose behalf we are processing your Personal Data.

    Legal Obligations

    We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

    Data that is Not Personal Data

    We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the services we provide to Brands and promote our business, provided that we will not disclose such data in a manner that could identify you.

    Data Security

    We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

    Data Retention

    We retain Personal Data about you in a manner consistent with our commitment to the Brand on whose behalf we such data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

    Personal Data of Children

    We do not knowingly process Personal Data from children under 13 years of age for our Brands; if you are a child under the age of 13, please do not attempt to register for or otherwise use the services we provide to Brands or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@gotoaisle.com.

    State Law Privacy Rights

    You may have certain rights with respect to the Personal Data about you that we process on behalf of Brands. In those circumstances, we are not the controller of your Personal Data and queries regarding such rights should be directed to the Brand. Please note that our Brands are independent third parties that maintain their own business practices and policies outside of their relationship with Aisle and their use of our services. As a result, unless provided otherwise in this Privacy Policy, we are not responsible for the privacy policies or data practices of our Brands, who may maintain separate policies and practices. To see how we process personal data of Aisle Audience users and website visitors, please visit Aisle’s [HERE].

    Contact Information:

    If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

    • 2012437578
    • gotoaisle.com
    • support@gotoaisle.com
    • P.O. Box 111. 160 Eagle Rock Ave, Roseland, NJ 07068

    Please recall, however, that because we process your Personal Data as a service provider on behalf of a Brand, please contact Brand, as the controller party in the first instance, to address your rights with respect to such data.