Privacy Policy

Revised as of December 15, 2023

Ocucom Corp dba Advertising Benchmark Index – ABX has created this Privacy Policy (the “Privacy Policy”) to explain what information is collected by or on behalf of its businesses operated under ABX (“ABX”) and/or its affiliate Ocucom (“Ocucom”, and collectively with ABX, “we” or “us”), why we collect certain information, how we use this information, and why and to whom we may disclose it.

This Privacy Policy applies to all personal information that we collect from and about individuals with whom ABX and/or Ocucom interacts (“you”), including individuals who visit the ABX website (https://www.adbenchmark.com) or the Ocucom website (https://www.ocucom.com/) (collectively, “our websites”); individuals who engage with ABX or Ocucom on LinkedIn, X (formerly Twitter), or other social media platforms; individuals who contact us by phone, email, or mail to inquire about or to discuss products or services that we offer or may offer in the future; individuals who a member of the ABX or Ocucom team communicates with or seeks to communicate with for business reasons; individuals whose contact information was provided to ABX or Ocucom by a business partner or other contact for business reasons; individuals included in our customer relationship management database; individuals who participate on research panels conducted at our request; and individuals who utilize our proprietary tools and solutions on behalf of a company or other entity that has engaged or is considering engaging our services.

By accessing our websites, contacting us, providing a member of our team your contact information, participating on research panels conducted at our request, and/or using our tools or solutions, you consent – on behalf of yourself and any company or other entity for whom you may be undertaking these activities – to all provisions stated in this Privacy Policy. If you do not agree with any provision of this Privacy Policy, please do not undertake any of the activities referenced above, as you do not have our consent to do so.

1. Overview

Your privacy is important to us. In operating our websites and providing our services, we follow all privacy laws applicable to data that we collect, store, or otherwise use. We also design and implement technical measures and organizational protocols aimed to ensure adherence to our principles and processes.

To demonstrate our commitment to your privacy, this Privacy Policy notifies you of:

Who we collect information from
What information we collect
How we collect and use your information
Where we store your information
Why and to whom we may disclose your information
Security procedures we have in place to protect the loss, misuse and/or alteration of your information under our control, and
The choices you have regarding collection, use and distribution of your information

Questions regarding this Privacy Policy may be sent to us at privacy@adbenchmark.com.

2. Who We Collect Information From

In conducting our business, we interact with different categories of people for different reasons. The information we collect from these different categories of people, and how we may use information we collect from or about them, is also different. To help you understand how we interact with your information, we’ve summarized various categories below.

	Category	Shorthand Name for People Engaging in Category
a.	Individuals who visit our websites and/or social media profiles for purposes of browsing, i.e., they do not submit a contact form to us through one of our websites or send us a Direct Message (DM) through social media(https://www.adbenchmark.com or https://www.ocucom.com/)	“Passive Website Visitors”
b.	Individuals who contact us by submitting a contact form through one of our websites; Individuals who engage with us on LinkedIn, X (formerly Twitter), and/or other social media platforms; Individuals who communicate with us by phone, email, mail, or in person, and inquire about or discuss our business, or any products or services that we currently offer, previously offered or may offer in the future; Individuals whose contact information was provided to us for business reasons by a business partner or other contact; Individuals who a member of our team communicates with or seeks to communicate with for business reasons; and Individuals included in our customer relationship management database.	“Professional Contacts”
c.	Individuals who participate on research panels conducted at our request	“Panelists”
d.	Individuals who utilize our proprietary tools and solutions, including individuals who interact in any manner with our proprietary portal, on behalf of themselves, or a company or other entity that has engaged or is considering engaging our services	“Clients”

Where we treat information differently based on category, we indicate that in this Privacy Policy by referring to the shorthand name shown above for people engaging in that category of activity. If you engage in more than one of the categories of activities above, we will treat your information according to each category in which you reside. Our use of the term “you” in this Privacy Policy refers to our treatment of information provided by any/all individuals with whom we interact, regardless of what category they are in.

3. Information We Collect

a. Personal Information

For purposes of this Privacy Policy, the phrase “Personal information” includes your name, usernames, current and previous company names, current and previous job titles, email addresses, postal addresses, and phone numbers.

Category of People	Do we collect your Personal Information?
Passive Website Visitors	No
Professional Contacts	Yes
Panelists	No
Clients	Yes

We do not collect personal information from individuals who participate on research panels conducted at our request.

We also do not collect personal information from people passively visiting our websites or social media profiles.

We do collect personal information from those visitors to our websites who affirmatively provide their contact information to us by submitting a form through one of our websites, as well as from people who we engage with (or who engage with us) through direct messaging (DM) on LinkedIn, X (formerly Twitter), and/or other social media platforms.

We also collect personal information from individuals who we communicate with by phone, email, mail, or in person, and who inquire about or discuss our business, or any products or services that we currently offer, previously offered or may offer in the future, as well as from individuals whose contact information was provided to us for business reasons by a business partner or other contact; individuals who a member of our team communicates with or seeks to communicate with for business reasons; and individuals included in our customer relationship management database.

Additionally, we collect personal information from current and prospective Clients when they affirmatively provide it to us or otherwise communicate with us about our services. We also collect personal information from Clients in connection with providing them services subject to one or more agreements entered by us and the Client. Our collection, storage and use of Clients’ personal information is typically detailed in such other agreement(s), which such other agreement(s) would control in the case of any conflict between any such other agreement(s) and this Privacy Policy.

Any personal information that you provide to us must be truthful and accurate, and you are responsible for notifying us about any changes necessary to keep such personal information current. We may combine personal information that we collect from and/or about you online (such as through HubSpot or LinkedIn), or that we learn about you through other means referenced above, with information that we collect from other sources. We may also retain your personal information for a period of time after we acquire it, for the purpose of recordkeeping, account management and fraud prevention activities.

b. Non-Identifying Information

Our websites are not set up to track, collect or distribute personal information not entered by a visitor. However, our websites do log certain non-identifying usage data, such as the number of visits you make to our websites.

For all categories of people above, we may also collect information about the internet protocol (IP) address used to connect your computer to the internet; connection information such as browser type and version, operating system and platform; other software and hardware information; and information about your browsing behavior, such as the date/time you visit one of our websites, the pages that you visit on our websites, the time you spend visiting our websites or viewing a page, the number of times you return to our websites, and other click-stream data. We treat all information of the type referenced in this paragraph as non-personal, unless required by applicable law to do otherwise. Additionally, we consider any unsolicited information that you provide to us to be non-confidential, and we are free to reproduce, use, disclose and distribute such unsolicited information to others without limitation or attribution.

We may use third-party website analytics tools (such as those offered by Google and LinkedIn) that collect information about visitor traffic on our websites. We use this information for internal purposes, such as to provide better technical support for our websites. We may also provide non-identifying information to third parties we engage to assist with support of our websites or our services, or for other business purposes.

4. How We Use Your Personal Information

Below is a summary detailing how we use the personal information that we collect from different categories of people:

Category of People	How We Use Your Personal Information
Passive Website Visitors	We do not collect or use personal information from Passive Website Visitors.
Professional Contacts	We may use personal information collected from Professional Contacts: To respond to your requests for/about our business and/or services To personalize your experience with our websites and/or services To keep you informed of updates about our websites and/or services To communicate with you regarding information that may be of interest to you relating to our company, services that we offer or may offer, and/or industries that we serve or may serve To improve our websites and/or our services, and/or To protect your rights, our rights and/or the rights of others
Panelists	We do not collect or use personal information from Panelists
Clients	We may use personal information collected from Clients: To respond to your requests To personalize your experience with our websites and/or services To keep you informed of updates about our websites and/or services To keep you informed of updates about your account To communicate with you regarding information that may be of interest to you relating to our company, services that we offer or may offer, and/or industries that we serve or may serve To improve our websites and/or our services, and/or To protect your rights, our rights and/or the rights of others

Professional Contacts or Clients who do not wish for their personal information to be used in one or more manners listed above, please follow the instructions provided in the “Opting Out” section below.

5. “Opting Out” of Communications

If you do not want personal information we collect from you to be used in one or more of the manners listed above, please send an email to privacy@adbenchmark.com with the subject line “Opting Out.” Please note that you cannot opt out from certain communications from us, including certain messages relating to our services.

6. Correcting or Deleting Your Personal Information

You have the right to request that we correct or delete your personal information. For individuals located in the EU, your right to request that we correct personal information that you believe is inaccurate, and to complete personal information that you believe is incomplete, is known as your “right to rectification”, and your right to request that we delete your personal information is known as your “right to erasure.”

If you want us to correct your personal information, please send an email to privacy@adbenchmark.com with the subject line “Request to Update Personal Information”.

If you want us to delete your personal information, please send an email to privacy@adbenchmark.com with the subject line “Request to Delete Personal Information”.

We will comply with your request, except as necessary for legal and/or compliance purposes.

7. Where We Store Your Personal Information

We securely store your data on servers under our control located in the United States. This means that any personal information collected in the EU will be transferred to the United States.

We implement a variety of security measures to maintain the safety of your personal information.

Personal information retained in our company records is transmitted via Secure Socket Layer (SSL) technology, and personal information retained in our company records is encrypted. Our authorization is required to obtain access rights to our systems. Personnel provided access to personal information by ABX or its affiliate Ocucom are required to keep this information confidential.

We also utilize data storage services provided by Amazon Web Services (“AWS”) and Google Cloud Platform (“GCP”). We maintain full control of data uploaded by ABX or Ocucom to AWS and/or GCP, including responsibility for configuring access to services and resources provided by AWS and/or GCP with respect to such data. For more information regarding AWS policies and protocols pertaining to data privacy and security, see https://aws.amazon.com/compliance/data-privacy-faq/, and for more information regarding GCP policies and protocols pertaining to data privacy and security, see https://cloud.google.com/terms/cloud-privacy-notice.

Unfortunately, no transmission of data over the internet, and no system for storage of data, is guaranteed to be completely secure. It may be possible for hackers or other third parties not under the control of ABX or Ocucom to intercept or access private communications unlawfully. While we strive to protect your personal information, ABX and Ocucom cannot ensure or warrant the security of any information you transmit or otherwise provide to us. Any transmission or other provision of information is done at your own risk.

8. How Long We Keep Your Personal Information

We will keep your personal data for so long as we need it to support the business purposes discussed in this Privacy Policy.

If you want us to delete your personal information sooner, please send an email to privacy@adbenchmark.com with the subject line “Request to Delete Personal Information”. We will comply with your request, except as necessary for legal and/or compliance purposes.

9. Why and to Whom We May Disclose Your Personal Information

We do not share your personal information with marketers, promoters or advertisers.

We may disclose personal information that we collect as summarized above to trusted third parties who assist us in operating our websites, providing our services, or otherwise conducting our businesses.

Personal information collected by ABX may be disclosed to its affiliate Ocucom Corp, and vice versa. Personal Information we collect may also be disclosed by ABX and/or Ocucom to any company with whom either of them may merge or which may acquire all or substantially all of ABX and/or Ocucom’s assets, and to any attorneys, accountants, or other trusted parties involved in any such transaction. Any party referenced in this paragraph would be required to keep your personal information confidential.

Additionally, we may disclose your personal information if we have a good faith belief that:

Access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, legal process (such as a court order or subpoena), request by law enforcement or governmental authority;
Such action is appropriate to enforce other policies relating to our websites or services, including any investigation of potential violations thereof;
Such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with our websites or services (including allegations relating to such issues); or
Such action is appropriate to protect the rights, property or safety of: (i) ABX, Ocucom, or any of their employees, contractors, or agents; (ii) other users of our websites or services; or (iii) any other person.

10. Information We Learn from Other Sources

We may receive or otherwise learn information about you from outside sources, such as updated address information provided by a postal service; professional information posted on LinkedIn; information available through Google; or information otherwise publicly accessible via the internet. We may use this information to inform the services that we offer or provide to you, including updating contact information for Professional Contacts and/or Clients.

11. Our Use of Cookies

Cookies are small files that a website transfers to your hard drive through your web browser, which enables a website to recognize a web browser, and to capture and remember certain other information. Certain third-party applications that we use to monitor anonymized data in connection with our websites (such as Google Analytics) may use tracking cookies to perform their functions. Additionally, our proprietary platform available to Clients uses login cookies, which assist Clients by remembering certain of the Clients’ login details so that the Clients do not need to enter their details again at each session.

If you wish to modify your preferences regarding cookies, check the “help” menu on your web browser, which should give you options for preventing, accepting, or receiving notice of use of cookies. Please be aware that if you block cookies, certain functionality pertaining to our websites or services may not be available to you. To learn more about cookies, visit www.allaboutcookies.org.

12. Links to Third-Party Sites

Our websites display links to websites operated by third parties (a “Third-Party Site”), such as links to the sources of articles in which ABX or Ocucom is featured. Third-Party Sites are not under our control, and we are not responsible for their content or operation. By providing links to Third-Party Sites, we do not approve, warrant, endorse, or otherwise make any representation about any such Third-Party Site, its owners or operators, or any goods or services that are or may be offered and/or sold by any of them.

If you click on a link to a Third-Party Site, you should read their privacy policy so that you are aware of their practices concerning collection, storage, and other use of your personal information. Visiting any Third-Party Site is at your own risk.

13. Compliance with U.S. State Privacy Laws

The privacy laws of certain U.S. states require a description of the types of information businesses collect about consumers, and the purposes for which such information is used. For ease of reference, the bullets below summarize where this Privacy Policy addresses these topics.

The categories of information that we collect about you, and the sources of this information, are explained in Sections 3 and 10.
The purposes for which we collect and use personal information is explained in Section 4.
The circumstances under which we may disclose your personal information is explained in Section 9.
The manner in which we retain personal information is explained in Sections 7 and 8.

We do not sell your personal information. We also do not “share” your personal information as that term is defined in the California Consumer Privacy Act, as amended (the “CCPA”, see https://oag.ca.gov/privacy/ccpa).

The privacy laws of certain U.S. states also provide the right for you to request information about how we collect, use, and disclose your personal information, as well as the right to access your personal information, correct your personal information; and request that we delete your personal information. Many state privacy laws also provide the right for you to opt out of certain forms of profiling and targeted advertising. We do not use your personal information for these purposes.

To request information about how ABX and Ocucom collects, uses, and discloses your personal information, see Section 19.
To request that ABX or Ocucom provide you with access to your personal information,
see Section 17.
To request that ABX or Ocucom correct or delete your personal information, see Section 6.

ABX and Ocucom respect your right to not be discriminated against for exercising any of your rights.

Additionally, the CCPA treats certain kinds of personal information, such as social security numbers, as “sensitive.” We do not collect any information that would be considered sensitive under the CCPA. Moreover, if any such sensitive information were to be collected by us in a specific instance, we would use such sensitive information solely for purposes permitted by the CCPA (e.g., to provide the services requested by the providers of such sensitive information).

To learn more about state data privacy laws currently in effect, follow the links provided below:

California Privacy Rights Act (CPRA) – https://oag.ca.gov/privacy/ccpa
Colorado Privacy Act (CPA) – https://coag.gov/resources/colorado-privacy-act/
Connecticut Data Privacy Act (CTDPA) – https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act
Utah Consumer Privacy Act (UCPA) – https://le.utah.gov/~2022/bills/static/SB0227.html
Virginia Consumer Data Protection Act (VCDPA) – https://www.oag.state.va.us/consumer-protection/files/tips-and-info/Virginia-Consumer-Data-Protection-Act-Summary-2-2-23.pdf

14. Compliance with EU Privacy Regulations – GDPR

Any organization that processes the personal data of people in the European Union must comply with the General Data Protection Regulation (the “GDPR”). As relevant to the GDPR, “personal data” is any information that relates to a person, such as their name, email address, and IP address, and “processing” is a broad term that covers practically anything you can do with data, including data collection, data storage, and data transmission.

Our practices comply with the GDPR. For more information regarding GDPR compliance, visit https://gdpr.eu/.

15. Children’s Online Privacy Protection Act Compliance

Our websites and services are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). Our websites and services are directed to people who are over the age of thirteen (13), and we do not knowingly collect any information from anyone under the age of thirteen (13). In visiting our websites and/or using our services, you agree that you shall not submit to us any personal information of any person under the age of thirteen (13) without the prior written consent of their parent or guardian.

16. Changes to this Privacy Policy

We may change this Privacy Policy at any time, for any or no reason, at our sole discretion, with or without notice, simply by posting such change(s) on this page. Any change will be effective immediately upon posting, and use of information by us is subject to the Privacy Policy in effect at the time of such use.

Your use of our websites and/or our services after any change signifies your acceptance of such change. We encourage you to visit this page on a regular basis to ensure that you are familiar with the most recent version of this Privacy Policy.

17. Requesting Access to Your Information

To request that we provide you with access to, or a copy of, your personal information collected, stored, transmitted, disclosed, or otherwise used by us, please send an email to privacy@adbenchmark.com with the subject line “Request to Access Personal Information”.

18. Reaffirmation of Consent

This Privacy Policy is a binding agreement that is personal between you and us. No other person shall be deemed a third-party beneficiary.

USE OF THIS WEBSITE SIGNIFIES YOUR AGREEMENT TO THIS PRIVACY POLICY.

19. Contact Information; Questions

If you have any questions regarding this Privacy Policy or our use of your personal information, please contact us by email at privacy@adbenchmark.com or by postal mail at the address below:

Privacy Director
Ocucom Corp dba Advertising Benchmark Index – ABX

333 Mamaroneck Avenue
White Plains, NY 10605

Should you wish to report a complaint, or if you feel that ABX or Ocucom has not addressed your concern in a satisfactory manner, contact your local authorities. If you require assistance with these efforts, contact our Privacy Director using the information provided above.

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