The purpose of this Throtle Website Privacy Policy is to explain how Throtle collects and uses information provided by users visiting our Website. This Privacy Policy applies solely to Website Data which is personal information collected on our corporate throtle.io website. Our throtle.io website is mainly directed to businesses that may wish to use our services, but we of course welcome consumers and others who want to know more about the data we collect and services we offer.  

Throtle also receives data from a variety of business partners, clients, and other companies that license data to us, or provide us data to facilitate our services. This information is referred to as Throtle “Service Data” and is covered in a separate Privacy Policy.  For additional information about Throtle’s broader privacy practices, including data collection and consumer rights related to its Service Data, please review the Throtle Service Privacy Policy here. 

I. Introduction to Throtle 

Throtle helps brands to use their own customer data, along with other licensed data, to improve customer interactions on multiple channels and devices. For instance, we provide data “onboarding” services to marketers engaged in online marketing (such as through use of Data Cookies), through our data management platform as well as other data services and platforms. 

We are a member of the Network Advertising Initiative (NAI) and adhere to the NAI’s Code of Conduct.  Throtle is also a member of the Interactive Advertising Bureau (IAB). 

II. Throtle Website Data – Types of Data Collected, How we Source the Data, and How We Use It 

Throtle collects personal information from your use of our website.  This includes information voluntarily provided by you including information passively collected about your interactions with our Website as describe further below: 

Personal Information you Provide: If you provide us with information through our website – for instance, if you give us your email to sign up for an event or webinar, or to request materials or information via our ‘Contact’ link on our webpage – we may request and receive certain information such as your name, email address, company name and phone number, or other information. 

We may use this information for any business purpose, including to administer your account, provide you services, to communicate with you in response to your request or other inquiries, to market to you, and to analyze how people use our websites. We may also provide the information to any successor entity, or during due diligence. 

Passively Collected Personal Information: Similar to other websites, we automatically collect information (or allow third parties to do so) when you visit our website via cookies, pixels/ web beacons or similar technology. We describe these technologies further in the section ‘Cookies, Pixels and Similar Technologies Used on our Sites’. This includes certain data that may be considered personal information depending on your jurisdiction such as cookies IDs or Mobile Advertising IDs (which we refer to us “UIDs”), IP addresses, internet service provider, referring and exit pages, and other web log data, including information about how you engage with our website (or if you are on another website, with our ads), as well as information about your browser or device. 

We may use this information for any business purpose, including to better understand how the website is being used and tailor your web experience, analyzing how visitors interact with our website, to market to you, and to deliver targeted advertising about goods and services that may be of interest to you. We may also use this information to target or “retarget” ads to you on other websites or mobile applications. For instance, if you spend time viewing a description of an event we are holding on our website, we might “retarget” you with an invitation to that event. We may also provide the information to any successor entity, or during due diligence. 

You may opt out of such targeting as set forth in the Opt-Out Options section below. 

Note that the Throtle Website may contains links to Third Party Sites such as social networks and other platforms (including career / employment application sites).  As one example, the Website may include buttons to “like” or “share” our social media pages (such as LinkedIn or Facebook).  If you click on these icons, you will be taken to those third party websites, and your use of those websites are subject to those privacy policies and practices.  Throtle is not responsible for the privacy of any third party. 

III. How We Share Data with Third Parties 

Throtle may share Website Data (including personal information you provide as described in the section above), with the following categories of Third Parties: 

Agents and Service Providers: We may share Website Data with agents and service providers who work on our behalf, or to help us provide services requested by our customers, and with our customers themselves. We may do so, for instance, for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, or other requested services. 

Affiliates, Parents, Subsidiaries and Successors: Throtle may share some or all of the data in our possession with affiliated or subsidiary companies. We may also share any data with a successor in interest who purchases all or most of our assets, or in the course of any transaction leading to such an acquisition, i.e., during due diligence. 

As Required by Law or to Protect Any Party: Throtle may disclose data if we believe that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us, or (b) to protect or otherwise defend the rights, property or safety of Throtle or any other party. 

IV. Cookies, Pixels and Similar Technologies Used on our Sites 

This section provides more information about cookies, pixels, and similar technologies that we may use on our Website. 

Cookies: Cookies are small text files that websites and other online services use to store information about users on users’ own computers. For instance, cookies are often used to store sign-in credentials and other preferences, so that you don’t need to enter them upon returning to a website. Cookies also often store information to make web viewing more customized to a particular user. Cookies also often store UIDs tied to your particular computer or browser, so that web services and third party ad networks can recognize you across different websites, over time. You may be able to configure your internet browser to advise you each time a cookie is being placed, and you may be able to refuse all or certain cookies altogether. However, if you refuse cookies (particularly first party cookies), this may interfere with certain website operations are optimized and customized to you, and may interfere with other important functions of websites. Throtle places cookies (and may allow third parties to place cookies) on our own website. We expire these cookies within 24 months (and often over a shorter time than that). 

Pixels or Web Beacons: Pixels, sometimes called web “beacons,” may also communicate information from your internet browser to a web server. Pixels can be embedded in web pages, emails and even videos, and can allow a web server to collect or read information from your browser, determine whether you have viewed particular web content or emails, or determine your IP address or the URL you are viewing content. We often work with business partners (who are themselves third party providers) to provide our services, and these partners often set and access their own cookies, pixel tags, and use other technologies to interact with your device, which may have cookies with varying expiration periods. These partners also may collect various types of information, often in pseudonymous or de-identified form, about your browser, device, or browsing activities through these cookies. 

V. Opt-Out 

First Party Cookie Opt-Out: As our First Party cookies are deployed to ensure the proper functioning of our website (such as prompting the cookie banner), website visitors are unable to opt-out of First-Party cookies. 

Third-Party Cookie Opt-Out:  If you would like to opt-out of other third party ad platforms and services (including some that we work with, and may have transferred data to previously), we recommend visiting the opt-out pages offered by the Network Advertising Initiative (the NAI), the Digital Advertising Alliance Web Choices Tool or the Digital Advertising Alliance CCPA Opt- Out Tool . Opting out in this way will not prevent you from seeing ads.  It will, however, generally prevent ads that are targeted to inferences made about your preferences based on your activity across websites and over time. 

Please note that if you browse the web from multiple browsers or devices, you will need to opt-out from each browser and/or device to ensure that we withhold our IBA services on all of them. For the same reason, if you procure a new device, change browsers or delete your Throtle opt-out cookie (or clear all cookies), you will need to perform this opt-out task again. 

Note that the Throtle.io website has third party cookies associated with Google Analytics as described in Section III.: How We Share Data with Third Parties. You may opt-out of data collection and sharing associated with Google Analytics / Google Tags which we use for website analytics either by visiting the opt-out page offered by the NAI, or by downloading the Google Analytics Opt-out Browser Add-on. 

Email Opt-Out: Throtle also offers the opportunity to opt-out of receiving promotional emails or communications from Throtle about our product and services.  Individuals may opt out of emails anytime by selecting the unsubscribe option within the email. 

VI. California Consumer Privacy Act and other State Consumer Privacy Laws 

The California Consumer Privacy Act of 2018 (“CCPA”), as well as laws recently enacted in Connecticut, Utah, Colorado, and Virginia, provide additional rights to individuals who reside in these states. 

As Throtle.io is designed to be a business-to-business corporate website, consumer information is generally not collected, shared, or sold as part of Website Data. However, consumers may learn more about Throtle’s broader privacy practices about data collection including instructions for consumers to exercise their state consumer privacy rights for our Service Data by referring to our Throtle Service Privacy Policy. 

If you would like to access or delete the contact information you provided to Throtle via the Contact webpage or for any other state consumer privacy inquiries or requests associated with Website Data, please email us at privacy@throtle.io. We will provide the same rights with respect to such information as set forth in the Throtle Service Privacy Policy.  If you would like to opt-out of any information collected or shared through first-party or third-party cookies used on our website, you may follow the guidance in the Opt-Out section above. 

VII. Security and Data Integrity 

Throtle takes steps to help ensure that the data we possess is housed and transmitted securely. We use multiple types and layers of physical and electronic security, including firewall protections, encryption of data during transfer, and strict access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we make substantial efforts to ensure that this does not occur. 

VIII. Updates to this Privacy  

We may update this Privacy Policy from time to time, such as to describe new types of data we collect or services that we offer. If you are interested in our data collection, use and sharing policies, we recommend that you check back to review these updates, as they occur. 

IX. International Users 

Our Website Data is generally stored on servers in the United States. If you are accessing our website, or if you are located in another country (such as a nation within the European Union), you should know that the laws governing various types of data in the United States may be different or less protective than those of your own country, and you may wish to consider that factor in deciding whether or not to opt-out of our services. 

X. Our Website is not Directed to Children Under 18 

Throtle is a business to business website and as such our website is not directed to children under the age of 18.  Throtle does not knowingly accept, process, or sell any personal information related to minors. 

XI. Questions or Concerns 

If you have questions or concerns about Throtle’s privacy efforts or products, please contact us at: 

ATTN: Privacy Officer 

Throtle, Inc. 

 141 West Front Street, Suite 312 

Red Bank, NJ 07701 

Or, you may email us at privacy@throtle.io.