Theorem Inc. (“Theorem”) is committed to taking reasonable steps toward protecting your privacy online and managing your information responsibly. This Privacy Notice is intended to notify you of our online privacy practices, the type of information that may be collected and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, and who to contact with questions or concerns.
This Privacy governs your use of, or interaction with, digital advertisements served by Theorem (the “Ads”), including but not limited to any advertisement you view, click on or link to, together with any information you may voluntarily provide in connection therewith, as well as websites owned or operated (the “Website(s)”) by Theorem and/or its affiliates (collectively, the “Company” or “we” or “us” or “our”).
This Privacy Notice describes our information handling practices related to advertising serving and tracking, as well as how we handle personal information we may obtain when you use any of the Websites, and how we may share it thereafter. This Privacy Notice does not apply to information we may obtain through other means, including offline or online in another forum.
This Privacy Notice does not apply to other third-party websites to which we may link, including the websites of our clients for whom we serve Ads. When linking to another website, you must review that website’s privacy notice as other websites may not treat information collected online in the same manner as we do.
By using the Websites, contacting us and/or by providing any personal information to us, you consent to the collection and use of information by us in accordance with this Privacy Notice. If we decide to change our Privacy Notice, we will post those changes on this page.
Why We Collect Information
We collect information because it helps us communicate to you about products, special offers, and information and events about which you might like to hear. We also collect your personal information to help us design and deliver our products and services, including the Websites, as well as measure the efficiency and conversion rate of the advertisements that we serve.
What Information We Collect
The following generally describes the type of information we may collect about you. Those who wish to communicate with us but do not wish to provide personally identifiable information online may contact us through the address or phone numbers provided on our corporate website, located at www.theoreminc.net. However, you should note that if you contact us by phone, email or via postal mail, you may still be submitting personally identifiable information to us.
Non-Personally Identifiable Information
We do not automatically collect personally identifiable information about you when you visit the Websites unless otherwise stated or you voluntarily input or submit such information, such as through registration on one of the Websites or otherwise. Should you voluntarily provide us with personally identifiable information, you consent to our use of it in accordance with this Privacy Notice.
Even if you do not submit personal information through the Network Websites, we may collect and store certain information automatically. This information, which is automatically obtained, may be used for marketing and analytical purposes and shared with our partners, vendors, clients and other third parties with whom we conduct business, and as otherwise required by law (such as to comply with a judicial proceeding, court order or subpoena). This information may include, but is not necessarily limited to:
- Internet Protocol (IP) address of the domain from which you access the Internet, either your individual address or the proxy provided by your Internet Service Provider (ISP). However, this information does not include your name or other personally identifiable information.
- Date and time you access a Website and the site of any advertiser whose website you accessed through one of our Ads.
- Web pages you view (recorded by the text and graphics files that compose that page), as well as click-stream data.
- Web address of the site from which you linked directly to our Website, as well as certain exit links.
- Browser version and operating system of the computer or mobile device you are using.
The information described above is generally used to drive advertising relevance, to maintain the quality of our offerings, and to provide general aggregate statistics regarding the use of the Websites and the interaction with the Ads. Such information is not personally identifiable. Geographic, demographic and category preference information across user profiles may be summarized for merchants advertising with us and for our partners and companies with whom we do, or seek to do, business. This helps prospective sponsors understand the viewership they will reach. The Company is the owner, co-owner or a licensee of the information it collects through the Websites and Ads.
We also may gather information about the technical efficiencies of our Websites and services (i.e., time to connect to the Websites, time to download pages, etc.). This information allows us to see which areas of our Websites are most visited and helps us better understand the user experience. This helps us improve the quality of the Websites by recognizing and delivering more of the features, areas and services our visitors prefer.
Personally Identifiable Information
In order to use some areas of our Websites, you may first be required to provide certain registration information, including certain personally identifiable information such as your name, age, email address, home address, educational and professional degree/certification information and related personal information. We may use this information to provide a more personalized experience (for example, providing better newsletter content, advertising and/or special offers that we think may be of interest to you).
We may also use your personally identifiable information to verify that you are who you claim to be, and to compare our Network visitors list to various lists received from other third-party companies, in an effort to target advertising messages. We also may correlate your personal information obtained from you with information from other sources. We do not share your personally identifiable information with third parties for any purpose other than data analysis.
How We Collect Information
We collect information in three primary ways:
- You Give Us Information: We collect information from you when you submit it to us through one of our Websites.
- We Collect Information Automatically: We automatically collect certain types of information when you visit our Websites or view our Ads. For example, we automatically collect various types of technical information when you use our Websites and place cookies when we serve our Ads, as otherwise described in this Privacy Notice.
- We Collect Information from Other Sources: We may obtain information about you from outside sources. We may also receive information from third parties who provide services for us as otherwise discussed in this Privacy Notice.
Information Collection Processes
Registration-based Targeting, User Targeting and Retargeting Using Cookies
Although we believe that cookies help enhance your experience on the Web by delivering more relevant messages to you, we do not need cookies to deliver ads to you. If you decline our cookie(s), you will still be able to view ads; however, they will not be optimized for your particular tastes or preferences, and you may see generic ads repeatedly.
We will not use shared local objects (commonly referred to as “FLASH cookies”) in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service. FLASH cookies are cookies that are placed on your computer that are not removed through normal browser management tools.
Web Beacons or Clear GIFs
In addition to cookies, Website pages and/or emails, as well as client websites linked to by the Ads, may contain electronic images known as pixel tags (also called “action pixels,” “web beacons” or “clear gifs”) and/or similar devices to identify you, to track your online activity for purposes of formulating future campaigns, and to help determine the effectiveness of a joint-promotional or advertising campaign. These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message that are used for such things as recording web pages and advertisements clicked on by a user or for tracking the performance of email marketing campaigns. These devices help us analyze online behavior and measure the effectiveness of the Ads, our Websites and our marketing efforts. We also work with third-party service providers that help us track, collect and analyze this information. Third-party entities with whom we have agreements may place these devices on the website and/or in e-mails to use information obtained from them such as pages viewed, items purchased, e-mails opened and items upon which you may click in e-mails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.
Ad Serving Software
How We Use the Information We Collect
We retain personal information submitted by you on a secure server. The personal information that you submit to us remains your property, but by submitting that personal information to us, you grant to us the right to use that information for marketing purposes, including sharing such information with third parties. For example, when you select to receive information about offerings from a third-party company during the registration process, we will share your personal information with that third-party company to carry out your information request. We may use your personal information to verify your professional and educational status and identity and/or to directly market certain offers to you (via advertising units or email). We may join together with other businesses to bring select offers to you based upon the personal information that you submit to us.
We reserve the right to release your personal information in the event that we believe that you are violating any of the terms or conditions (including this Privacy Notice) of the Websites, using the Websites to commit unlawful acts, if such information is subpoenaed, if we are acquired, or when we deem it necessary or appropriate. By agreeing to the terms of this Privacy Notice, you hereby consent to disclosure of any record or communication to any third party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your email address with other third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time and Federal Trade Commission enabling regulations, or any other applicable law, rule or regulation.
You also agree that we, and other third parties, may contact you via email, direct mail and telemarketing for feedback purposes and surveys.
In addition, if you register on our Websites by providing your personal information, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”). Notwithstanding that your telephone number may be listed at the Federal Trade Commission’s Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the Rule.
We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from customer lists, analyzing data and providing marketing analysis. These agents may have access to your personal information as needed to perform their functions for us.
We will not rent, sell or share any personal information we gather from you to third parties, except as indicated herein or to provide information regarding the products or services you have. Notwithstanding the foregoing, we may provide your personal information to third parties for data services, which may include, but not are not limited to, data cleansing, merge-purge, appending, campaign effectiveness analysis, and mapping or for other purposes we deem important to the services we provide.
We may transfer your personal information to our subsidiaries and corporate affiliates, or in connection with the reorganization or sale of the Company, or the sale of all or substantially all of the Company’s assets.
You may opt-out of receiving marketing email messages from the Websites either when you register with the Website or at a later date. To opt-out of receiving emails after registration, you must follow the process established by the Website. At minimum, there should be an unsubscribe process defined in any commercial email.
Your Choices about the Information We Collect
If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails or opt-out in your account profile, or as set forth herein.
If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be.
How to Opt-out
If you no longer want to have the data you have provided through registration-based or user targeting used to help improve the relevance of your online advertising experiences, you can manage your permissions and opt-out. If you choose to opt-out, we will drop a cookie on your browser indicating that you do not want to be tracked. While it sounds counterintuitive, this is the standard industry practice. The cookie that we will drop will just have one field indicating that you have chosen not to be tracked. Please note that if you delete, block or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice, as our opt-out is cookie based, and may be removed or disabled by such actions. If you have opted out and wish to opt back in you may use the cookie settings in your browser to clear your opt-out cookie.
If you no longer want to have the data you have provided through advertising software (as detailed above) help improve the relevance of your online advertising experiences, you can manage your permissions and opt-out at https://www.google.com/settings/ads/onweb.
Privacy of Children Who Visit the Website
We recognize the unique privacy concerns regarding children. We are committed to carefully protecting privacy where children are involved no matter the point of contact. In particular, our intention is to fully comply with the Children’s Online Privacy Protection Act (“COPPA”). Pursuant COPPA guidelines, we do not knowingly collect personal information from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided us with personal information through any point of contact, please contact us and we will delete the information about the child referenced from our files.
Notice to California Residents
A business subject to California Civil Code § 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of information disclosed, for the third party’s direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request to:
26 Main Street, Suite 302
Chatham, NJ 07928
Please note that the Company is only required to respond to a customer once during any calendar year.
Limitation of Liability
IN NO EVENT SHALL THE COMPANY BE LIABLE FOR ANY INCIDENTAL, CONSEQUENTIAL, INDIRECT OR SPECIAL DAMAGES (INCLUDING LOST PROFITS), WHETHER BASED ON WARRANTY, CONTRACT, TORT OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT WE ARE ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE LIMITATIONS SET FORTH IN THIS PARAGRAPH MAY NOT APPLY TO YOU. IF THE FOREGOING LIMITATIONS ARE HELD INAPPLICABLE OR UNENFORCEABLE FOR ANY REASON, THEN THE MAXIMUM LIABILITY OF US TO YOU FOR ANY TYPE OF DAMAGES SHALL BE LIMITED TO THE GREATER OF THE ACTUAL DAMAGES SUFFERED BY YOU OR THE AMOUNT OF MONEY YOU PAID TO US IN CONNECTION WITH THE SERVICES OR ACT WHICH RESULTED IN THE ALLEGED DAMAGES.
Acceptance of this Privacy Notice
This Privacy Notice is governed by the internal substantive laws of the State of New Jersey in the United States, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Notice shall lie exclusively with the state and federal courts within the State of New Jersey. If any provision of this Privacy Notice is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions, which shall remain in full force and effect. The failure of the Company to enforce any term or condition of this Privacy Notice shall not be deemed a waiver thereof and shall not prevent its later enforcement.
Rights to Information
You hereby grant Company an irrevocable, perpetual, worldwide right and license to use and display all information submitted by you in accordance with this Privacy Notice.
You may be able to link from Websites to third-party websites (“Linked Websites”). In addition, the Company may work with third parties (for example, advertising agencies, audience measuring and auditing services, etc.) who may also gather information, including potentially personally identifiable information, about you from or through your use or viewing of our Websites or Ads contained on any other website. You acknowledge and agree that we have no responsibility for the information, content, products, services, advertising, code or other materials which may or may not be provided by or through Linked Websites. Links to Linked Websites do not constitute an endorsement by us of such websites or the information, content, products, services, advertising, code or other materials presented on or through such websites.
The Company disclaims any liability for: (1) links from another website to our Websites; (2) links to a Linked Website from our Websites; and (3) any of our Websites or information contained thereon. The Company cannot guarantee the standards of any website to which links are provided on any of our Websites, nor shall the Company be held responsible for the contents of such non-Company sites, or any subsequent links. For this reason, the Company does not represent or warrant that the contents of any third-party website are accurate, compliant with state or federal law, or compliant with copyright or other intellectual property laws. Also, the Company is not responsible for webcasting or any other form of transmission received from any Linked Website. Any reliance on the contents of a third-party website is done at your own risk, and you assume all responsibilities and consequences resulting from such reliance.
Visitors to the Website Outside of the United States
If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using this Website and/or submitting information to us, you specifically consent to the transfer of your information to the United States, to the facilities and servers we use, and to those with whom we may share your information.
We employ procedural and technical safeguards to secure your personal information against loss, theft, alteration, and unauthorized access, use and disclosure. We also employ many security procedures to protect your information from unauthorized access by users inside and outside the Company. We also protect your information offline. All of our users’ information is restricted in our offices. Only employees or contractors who need the information to perform a specific job are granted passwords to access personally identifiable information.
While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable, and we cannot guarantee that only authorized persons will view your information. You can reduce these risks by using commonsense security practices such as choosing a strong password, using different passwords for different services and using up-to-date antivirus software. Regardless of the precautions taken by us and by you, we cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.
If you have any questions about this Privacy Notice please email firstname.lastname@example.org or contact us via postal mail, Attn: Privacy Manager, at:
26 Main Street, Suite 302
Chatham, NJ 07928
Theorem Inc. (“Theorem” or the “Company”) is a Delaware corporation. The Company has its principal place of business located at 26 Main Street, #302, Chatham, New Jersey 07928, USA. This statement (“EEA/Swiss Privacy Statement”) sets forth the privacy standards that Theorem utilizes to collect, retain, and use personal information obtained from individuals located within the European Union (“EU”), the European Economic Area (“EEA”) and Switzerland. It is Theorem’s policy to respect, and protect, personally identifiable information from individuals in the EU/EEA and Switzerland as set forth in this EEA/Swiss Privacy Statement.
What Is the Scope of this Statement?
“Data” means Personal Data (as defined below) and Sensitive Data (as defined below) collectively which is received from, or about, persons located within the EU/EEA or Switzerland.
“Personal Data” means information received from, or about, persons located in the EU/EEA or Switzerland that relates to an identified or identifiable individual, including information that can be linked to an identified or identifiable individual. Personal Data may also include “Sensitive Data.” Personal Data can include information supplied to us by you, or which is received from other sources.
“Sensitive Data” is a subset of Personal Data that is information from, or about, persons located in the EU/EEA or Switzerland relating to medical or health status; racial or ethnic background; political opinions, religious or philosophical beliefs, trade union membership, information relating to sex life or sexual orientation, and information relating to actual or alleged criminal history. Sensitive Data also includes any information that you (or the person/entity from which the information was obtained) advise(s) us that the Data is sensitive and the Data is treated as sensitive.
“Transfer” or “Transferred” includes communicating, disclosing, or accessing by electronic or other means, whether at the premises where the information is physically located, by remote access, or otherwise.
“we,” “our,” “us,” or the “Theorem Entities” means Theorem, Theorem India Pvt. Limited, and Theorem EMEA Pvt. Ltd.
Notice: If you are asked to submit Data to us, we will advise you of the types of Data we may collect about you, the purposes for which we collect and use your Data, and the types of third-parties to which we may disclose your Data. Notice will be provided in clear and conspicuous language at the time of collection, or as soon thereafter as is practicable before disclosing it to a third-party. We will also advise you of any new uses for which we may collect and use your Data as soon thereafter as is practicable. Depending upon the type of Data which you are asked to submit, we may advise you in different ways, including electronically if you are asked to submit information via e-mail or through a website or portal of ours. We will also advise you how to contact us with any inquires or complaints about the collection, use, or handling of your Data.
Consistent with these principles, we may not be in a position to be able to provide you with notice prior to disclosing your Data under certain limited circumstances such as, if we have to respond to a subpoena or other legal process, if disclosure is allowed under law, or if we need to disclose such information for other legitimate purposes which might include preventing fraud, protecting the Data, and/or guarding against or defending any potential liability.
Choice: With respect to Personal Data we gather from you, we will offer you the opportunity to decide whether your Personal Data should be disclosed to a third-party, or if your Personal Data is to be used for a purpose incompatible with the purpose for which it was originally collected. With respect to Personal Data, we will provide at least “opt-out” notice. “Opt-out” means that when you are advised of the types of Personal Data, proposed use, and types of parties to whom it may be disclosed, if you do not affirmatively take some action indicating that you do not wish us to collect, use, or disclose your Personal Data, we will deem your inaction an implicit consent to collect, use, and/or disclose your Personal Data.
In the event that the Data is, or includes, Sensitive Data, you will be given the ability to explicitly choose whether the Sensitive Data may be disclosed to a third-party, or if the Sensitive Data is to be used for a purpose incompatible with the purpose for which it was originally collected by explicit opt-in choice. “Opt-in” choice means that when you are advised of the types of Sensitive Data, proposed use, and types of parties to which it may be disclosed, if you do not affirmatively take some action indicating that you specifically consent to allow us to collect, use, or disclose your Sensitive Data, then you will not have consented to the collection, use, or disclosure of your Sensitive Data for a purpose other than those for which it was first collected or subsequently authorized by you. The opt-in notice for Sensitive Data may be limited to the extent allowed under applicable law.
We will advise you with clear conspicuous, readily available, and affordable mechanisms to exercise your choice.
Onward Transfer: We will only Transfer your Data to third-parties apart from the Theorem Entities if the third-parties: (a) have provided satisfactory assurances that they will adhere to privacy practices providing at least the same level of privacy protection as set forth in this statement; (b) are subject to EU/EEA or Swiss data privacy laws or the data protection laws of another country which EU/EEA or Swiss data protection authorities, as the case may be, have deemed provide “adequate” data privacy protections; (c) have agreed to model contractual clauses deemed “adequate”; or, (d) have certified under the applicable Privacy Shield Framework. If we have knowledge that a party to which we transfer information is using or sharing the Data in a way contrary to the principles set forth in this statement, we will take reasonable steps to attempt to stop or prevent the processing. If we fail to comply with these terms, we may be subject to liability.
Security: We take reasonable precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. To the extent that we have any Sensitive Data, we will take greater care to protect the Sensitive Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Data Integrity: The Data we collect will be necessary for, and related to, the purposes for which it has been collected. We will not process Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual concerned. We will take reasonable steps to ensure that the Data is reliable, accurate, complete, and current for its intended use
Access: We will provide you with reasonable access to your Data so that you may review what information we may have about you. You may request corrections, deletions, or additions as may be reasonably appropriate, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. There may be other times when we may limit, or prevent, your access to your Data as permitted by applicable law.
Enforcement: We encourage any person who has questions or complaints about our privacy practices under this statement to contact us at the contact information set forth below. We will seek to investigate any claims, address any concerns, and resolve any disputes made concerning the handling of Data in connection with the Principles of this EEA/Swiss Privacy Statement. We will take steps to remedy any breaches of the Principles of this EEA/Swiss Privacy Statement.
Dispute Resolution: Individuals in the EU/EEA or Switzerland with inquiries or complaints regarding this EEA/Swiss Privacy Statement should first contact Theorem at
26 Main Street, #302
Chatham, New Jersey 07928, USA
Attn: Privacy Officer
Limitation on Scope of Principles: Our adherence to these principles may be limited to the extent required to meet legal, governmental, national security, or public interest obligations.
Questions or comments about this statement, or any requests for access, or complaints, whether or not applying to Theorem, should be submitted to the following address:
26 Main Street, #302
Chatham, New Jersey 07928, USA
Attn: Privacy Officer
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