Thanks for using ACT360 Ads manager or visiting one of our websites. This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell lists or email addresses.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “ACT360,” we are referring to The A.C.T. Three Sixty Pvt. Ltd., a company registered with Office of the Company Registrar, Kathmandu, Nepal. We provide online platforms that you may use to market to customers or design campaigns to run the campaigns in various platforms including creating, managing and distributing your ads to multiple platforms others. When we say “Member,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to a Member or to some other person who visits any of our Websites. A “Platform” is a company / entity / publisher you choose to use in order to show your ads on. A “customer” is the end person who views or is able to view ads delivered by you using our software when visiting or using services of various platforms you distribute your ad in. “Personal Information” means information that can be used to identify you or a Customer, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.
4. Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:
Attn. Privacy Officer
Adrishya Building, Lal Durbar Marg, Hattisar
5. Information We Collect
(c) Platform and related information: When you add a platform or create a campaign with the Services, we have and may access the data on your platform and the information in your campaign.
(d) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.
(f) Information from other sources: We may receive more information about you or your Customers, such as name, email address, demographic information, IP addresses, location, and use of social media websites, by searching the Internet or querying third parties (we refer to that information as “Supplemental Information”). We use Supplemental Information to develop features including Social Profiles, a tool that helps you learn about your Customers and allows you to send them more relevant content.
6. Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
(a) To promote use of our services to you. For example, if you leave your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using.
(b) To send you informational and promotional content that you may choose (or “opt in”) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
(c) To bill and collect money owed to us by our Members. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number (or a different online wallet account information). We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
(e) To communicate with our Members about their account and provide customer support.
(g) To protect the rights and safety of our Members and third parties, as well as our own.
(h) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
(i) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
(j) To prosecute and defend a court, arbitration, or similar legal proceeding.
(k) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
(l) To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Customers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Customers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
(m) To provide suggestions to you. This includes adding features that compare Members’ campaigns, using data to suggest other publishers your Customers may be interested in, or using data to suggest products, services or platforms that you may be interested in or that may be relevant to you or your Customers. Some of these suggestions are generated by use of our Data Science Projects.
7. Data Collected for and by our Users
As you use our Services, you may import into our system Personal Information you have collected from your Customers or other individuals. We have no direct relationship with your Customers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Customers to companies that help us promote, provide, or support our Services or the services of our Members (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about Customers. We may share this information, including Customer email addresses, Customer Social Media profiles or Customer profiles in any platforms (that you integrated with our Services) with third parties in line with the approved uses in Section 6.
If you are a Customer and no longer want to be contacted by one of our Members, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
8. Public Information and Third Party Websites
(a) Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.
(b) Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
9. Third Parties
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
(a) Service providers. Sometimes, we need to use third party Service Providers in order to provide and support the features of our Services. For example, if it is necessary to provide you something you have requested (like send you a T-shirt or enable a feature such as Social Profiles), then we may share your Personal Information with a Service Provider for that purpose. We will tell you we are working with a Service Provider whenever reasonably possible, and you may request at any time the names of our Service Providers. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information in a manner that is consistent with this policy.
(b) Advertising partners. We may partner with third parties to display advertising on our Websites or to manage our advertising on other sites and may share Personal Information with them for this purpose. All third parties with which we share this information enter into a contract with us that requires them to use your Personal Information in a manner that is consistent with this policy. We or our third party partners may use technologies, such as cookies, to gather information about your activities on our Websites and other sites in order to provide you with advertising based on your browsing activities and interests.
- Contest and Sweepstakes
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
11. Content of Marketing Campaigns
When you create and run a marketing campaign, it goes to various servers and platforms across the Internet. Along the way, server administrators and users of platforms can read what you put in the campaign. Please do not use ACT360 to send confidential information.
YOUR Audience Lists
12. Your Audience Lists
A Audience List can be created in a number of ways, including by importing contacts, such as through csv, directly from your social profile or by creating an audience using our services. Your Audience Lists are stored on a secure ACT360 server. There are two kinds of Audience lists : Public and Private. We do not, under any circumstances, sell your Private Audience Lists. If someone on your Audience List complains or contacts us, we might then contact that person. Only authorized employees have access to view Audience Lists.
We will use and disclose the information in your Audience Lists only for the reasons discussed in Sections 6-9. We will not use and disclose the information in your Audience Lists to:
- bill or collect money owed to us;
- send you system alert messages;
- communicate with you about your account; or
- send you informational and promotional content.
If we detect abusive or illegal behavior related to your Audience List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organizations.
13. Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then ACT360 will notify you as soon as possible and later report the action we took in response.
14. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our online wallet processing vendor uses security measures to protect your information both during the transaction and after it is complete. If you have any questions about the security of your Personal Information, you may contact us at email@example.com
ACT360 accounts require a facebook account to log in. You must keep your Facebook username and password secure, and never disclose it to a third party. Because the information in your Audience Lists is so sensitive, we rely on FB’s security checks for access, which means we cannot see your passwords / or account information on Facebook. We cannot resend or reset forgotten Facebook passwords either.
15. We Operate around the world
Our servers are located in cloud (Amazon Web Services) so the data may go to any physical location where Amazon has a Data Center. Our offices are located in Nepal, so your information may be transferred to, stored, or processed in Nepal and in any location where Amazon Web Services stores its data. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities worldwide and those third parties with whom we share it as described in this policy.
16. Accuracy of Data, Transparency, and Choice
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information.
We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
As explained in Sections 6 and 9 of this policy, ACT360 shares your Personal Information and the Personal Information you may have collected from your Customers with Service Providers in order to provide and support our Services. With respect to Personal Information we share with our advertising partners, you have a choice.
We will give an individual, either you or a Customer, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us here. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Customer, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.
21. Do Not Track Disclosure
“Do Not Track” is a standard that is currently under development. Because it is not yet finalized, ACT360 adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.