Effective Date: 01/01/2021

Philico Investments, Inc. (“Philico”, "we", "us") provides a partner marketing platform, LeadDash™ (“SAAS platform”, “Site”). Philico is committed to protecting the privacy of your personally identifiable information. We provide this privacy policy ("Privacy Policy") in order to explain our online information practices about the way your information is used in our SAAS platform. It does not state the policies of clients’ websites, or apps on which ads are shown. Clients’ use, collection or any other use of end user data is governed by their own privacy policies and applicable laws, rules and regulations.

Client Information. We collect personally identifiable information when Client agrees to use LeadDash™ as their partner marketing platform. Personally identifiable information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: business entity name and/or your title with the applicable business entity, as well as your personal and/or business entity related e-mail address, mailing address, daytime and/or cellular telephone numbers, fax number, account information (or other information that we require in order to collect payment due for services rendered). We use your personally identifiable information: (a) to send you information regarding your account; (b) to track your compliance with the Terms of Services ("Terms of Services "); and/or (c) for validation, suppression, content improvement and feedback purposes. For purposes of this Privacy Policy, your account information shall be considered "Sensitive Information.”

Clients’ Usage of LeadDash™ and Collecting Information. Clients may use LeadDash™ for pixel and server postback tracking to collect certain marketing information about the end users. For pixel tracking LeadDash™ stores no personally identifiable information when the user engages with our platform by interacting with an advertisement. This information can be in the form of a session identifier, cookies, or the user's public IP address. Pixel tracking stores a session identifier in a user’s browser cookie on click. In postback tracking, LeadDash™ directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to LeadDash™ for validation. With either method, when an end user clicks on a Client’s ad (text link, or image), and lands on a specific web page or mobile app, LeadDash™ collects information from the user’s device including but not limited to IP address and ad identifiers. Clients may use LeadDash™ to process information from end users. This information may be used to measure performance of ad campaigns, and serving non-targeted ads using data that does not personally identify users.

End User Information. We may collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or request information by completing a form on this Site, such as the type of browser you are using (e.g., Chrome, Firefox, Edge, Internet Explorer), the type of operating system you are using, (e.g., Windows, iOS), device type (Android, Apple) and the domain name of your Internet Service Provider (e.g., Cox, Verizon). We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.

Information Sharing. We will not sell, share or rent your personally identifiable information to or with others. We may, from time to time, provide such information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services in connection with improvements to LeadDash™. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us.
Further, we reserve the right to share your personally identifiable information: (a) where required by law, or requested by a court of competent jurisdiction; (b) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; (c) where you are in violation of this Privacy Policy, the Terms of Services; (d) in the case of a dispute; or (e) where we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.

International Transfer of Data. As part of being a LeadDash™ Client, we may transfer information that we collect about you and your end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your end users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your end users, including personal information, as described in this Privacy Policy.

Data Retention. Under the EU's General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) LeadDash™ is classified as a Data Processor. You have the right as a data controller to request information about the processing of your data, correct your data, delete or block your data, restrict the processing, object to the processing of your data, revoke your consent to the processing of your data in the future, complain about inadmissible data processing. If you would like to update, limit, remove, or correct your information, please contact support@LeadDash.com.

Third Party Links. The Site may contain links to third-party websites ("Third Party Websites"). Please be aware that we are not responsible for the privacy practices of Third Party Websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Site.

Security. We endeavor to safeguard and protect our Clients’ information. When Clients submit personally identifiable information, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit Sensitive Information (such as bank account information and/or credit card information), and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we protect all other user information online and offline. The Third Party Agent servers that we utilize to store personally identifiable information in are kept in a secure physical environment. The Third Party Agent has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.
Please be advised that, although we take every reasonable precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your information will be absolutely secure. Any transmission of data at or through our Site is at your own risk. However, access to your personally identifiable information is strictly limited, and not accessible to the public. Only employees, and third party agents, that need the information to perform a specific job are granted access to personally identifiable information. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
You acknowledge that you provide your personally identifiable information to us with knowledgeable consent and at your own risk.

Deleting and Updating Your Information. If you would like to delete or update the personally identifiable information that we have collected from you, simply email us at: support@LeadDash.com.
We will process your request, where possible and subject to the terms of services contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

Opting Out of Receiving E-mail. You may at any time choose to stop receiving emails containing general information regarding Philico Investments, LLC by following the instructions at the end of each such email or by contacting us at support@LeadDash.com. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Account, as well as to respond to any inquiry or request made by you.

Notification of Changes. We reserve the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the Site explaining that we are changing our Privacy Policy. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.

Contact Us. If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us at: support@LeadDash.com.