Effective: 04/27/2021
1. Introduction and Overview.
Astronomie, a division of Kepler Group LLC (together with its affiliated companies, “Kepler, “we,” “our,” or “us”), is a marketing services company. This Privacy Policy describes how Astronomie collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of any online service location that posts a link to this Privacy Policy, including our corporate website at www.astronomie.io, and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). By using the Service, you agree to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.
This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below, at the time of collection, or for any offline location that makes this Privacy Policy available to you). For information about processing on behalf of our clients, please see the “Information on Behalf of Our Clients” section below.
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below. If you are a California resident or data subject in the European Economic Area, please see the “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” sections below.
2. Information Collection.
A. Information You Provide.
We collect information that you provide directly via the Service, such as when you access our content, contact customer support, or apply for a job. We may use Service Providers (defined below) to collect this information.
The information we collect includes information that identifies you personally (whether alone or in combination). The categories of information we collect and have collected in the last 12 months include:· Contact Data. We collect your first and last name, e-mail address, postal address, phone number, business details, and other similar contact data.
You may choose to voluntarily submit information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
We automatically collect information about your device and how your device interacts with our Service and other services. We may use Service Providers to collect this information. The categories of information we automatically collect and have collected in the last 12 months include:
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
For further information on Tracking Technologies and your rights and choices regarding them, see the “Social Media and Technology Integrations,” “Analytics and Advertising,” and “Your Rights and Choices” sections below.
C. Information on Behalf of Our Clients.
We provide agency services for our clients, such as campaign strategy and media buys, and collect and process information about individuals (including through Tracking Technologies) at the direction of our clients (“Client Data”). Client Data has historically included contact data, demographic data, content, service use data, device connectivity and configuration data, and location data, among other information. Our processing of Client Data is governed by the terms of our service agreements with our clients and their privacy policies, and not this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.
We acknowledge that you may have rights in connection with Client Data. If your information has been processed by us on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make you request directly to us, please provide the name of the Astronomie client on whose behalf we processed your information. We will refer you request to that client, and will support them to the extent required by applicable law in responding to your request.
For further information on your rights and choices regarding Client Data, see the “Your Rights and Choices” section below.
D. Information from Other Sources
We also obtain information about you from other party sources. The categories of other sources from which we collect or have collected information from in the last 12 months include:
3. Use of Information.
We use information we collect for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purpose for collecting and using information, including in the last 12 months, include to:· Operate and manage our Service.
Notwithstanding the above, we may use information that does not identify you (including information that has been de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the “Your Rights and Choices” section below.
4. Sharing of Information.
We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information with in the last 12 months include:
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the “Your Rights and Choices” section below.
5. Social Media and Technology Integrations.
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by other parties, and/or integrations with technologies operated or controlled by other parties. In addition, we may host parts of our service on other party platforms. For example, we may offer our content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. If you publicly reference our Service on another party’s service (e.g., by using a hashtag associated with Astronomie in a tweet or post), we may use your reference on or in connection with our Service.
These other parties may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by other parties, whether through our Service, or another party’s service or device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We are not responsible for and makes no representations regarding the privacy practices of such other parties. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
6. Analytics and Advertising.
Our Service contains Tracking Technologies, some of which are owned and operated by other parties. For example, we use Tracking Technologies from analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other parties to serve advertisements. These other parties may use Tracking Technologies on our Service (including in emails) and other services (including in advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and other services after you have left the Service (“Interest-based Advertising”).
Astronomie may help its clients with analytics and advertising services, including through the use of Tracking Technologies and matched ad services. Our processing of Client Data is governed by the terms of our service agreements with our clients and their privacy policies, and not this Privacy Policy. For more information about processing on behalf of our clients, please see “Information on Behalf of Our Clients” section above.
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
7. Your Rights and Choices.
A. Tracking Technology Choices.
Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
B. Analytics and Interest-Based Advertising.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Some of the parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members for websites, please visit http://www.aboutads.info/choices. In addition, some of these other parties may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Communications.
You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Astronomie’s ongoing business relations.
Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions.
8. Children.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Astronomie does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Astronomie has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
9. Data Security.
We implement reasonable security measures designed to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
10. International Transfer
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in Europe, we will transfer your personal data subject to appropriate or suitable safeguards, such as the Standard Contractual Clauses.
11. Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. If we make any material or substantive changes, we will post a clear and conspicuous notice of those changes on the Services and in this Privacy Policy, and may provide you additional notice to your e-mail address. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted.
12. Contact Us.
If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:
By E-mail:
By mail:
Astronomie, Privacy Officer; 6 East 32nd Street, Floor 7; New York, NY 10016
13. Additional Disclosure for California Residents.
A. Roles.
Our Service is intended to provide information to our clients and job applicants. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Astronomie conducting due diligence regarding, or providing or receiving a product or service to or from your employer.
We acknowledge that you may have rights in connection with Client Data. If your information has been processed by us on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of the client on whose behalf we processed your information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request. For more information about processing on behalf of our clients, please see “Information on Behalf of Our Clients” section above.
B. Shine the Light.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Astronomie may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” above. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Astronomie is not required to respond to requests made by means other than through the provided e-mail address or mail address.
14. Additional Disclosures for Data Subjects in Europe.
A. Data Controller.
Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).
Astronomie acts as a controller with respect to personal data collected as you interact with our Service. However, in most instances, Astronomie acts a processor on behalf of a client, which is the controller. Please visit the applicable client’s privacy policy for information about their privacy practices. Any questions that you may have relating to the processing of personal data by Astronomie on behalf of the client and your rights under data protection law should be directed to the client as the controller, not to Astronomie.
B. Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our Service Providers, partners, or clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
C. Your European Privacy Rights.
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” above and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
We acknowledge that you may have rights in connection with Client Data. If your information has been processed by us on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of the client on whose behalf we processed your information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request. For more information about processing on behalf of our clients, please see the “Information on Behalf of Our Clients” section above.
D. Complaints.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. In addition to the contact information above, for EU-specific requests, you can reach us at infosec@Astronomie.io.
