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Privacy Policy

Effective July 26, 2019

Spotfront, Inc. (“Spotfront,” “we,” “us,” or “our”) is deeply committed to protecting the privacy of internet users. This privacy policy (“Privacy Policy”) covers the treatment of information collected on the website located at (the “Site”) and the services, applications, and features made available at the Site (collectively with the Site, the “Services”).

This Privacy Policy does not apply to information collected through Spotfront’s PromoteIQ service platform (“PromoteIQ Service Platform”).  For the terms governing information collected through the PromoteIQ Service Platform, please review your Master Services Agreement with Spotfront (or such similar agreement as may be agreed to by you and Spotfront).

Furthermore, these privacy practices apply to Spotfront’s marketing activities, prospective customers, and users of the Site. This policy does not apply to third parties that Spotfront does not own or control.

Any order forms or additional agreements governing specific optional Spotfront features shall take precedence over the terms of this Privacy Policy to the extent of any differences, so please read such order forms or additional agreements carefully.

1. Data Policy

Information Collected by Spotfront

Automatic Information

We receive and store certain types of information whenever visitors (“you,” “users”) interact with us through the Services.  For example, Spotfront automatically receives and records traffic data on our server logs from your browser, including your IP address, Spotfront cookie information, and requested pages. Spotfront uses this traffic data to analyze trends and administer the Site. Our Site and Services also automatically collect usage information, such as the numbers and frequency of visitors to our Site and its components. This data is only used in the aggregate. This type of collective data enables us to figure out how often users use different parts of the Site and Services. In addition, we may provide statistical collective user information to our partners so that they understand how often people use specific components of our Site and Services, but such information does not identify you personally.

In the course of delivering an ad to you, Spotfront does not collect personally identifiable information (“PII”) about you. PII includes data such as your name, address, phone number, social security number, or email address. Spotfront does collect non-personally identifiable information about you when delivering an ad, for the purpose of targeting ads and measuring the effectiveness of ads on behalf of Spotfront’s advertisers. This non-personally identifiable information includes data such as:

    • Domain Type – .com, .net, .edu, etc.
    • Standard Data – common information found in every communication sent over the internet. Using this information, Spotfront can infer information such as browser type; operating system; browser language); and internet service provider
    • Clickstream Data – Spotfront can infer how you use our advertisers’ sites and various pages on the internet.

Spotfront may use this non-personally identifiable information to create data segments, and these data segments are generally based on the websites that you visit. Spotfront does not collect data or create data segments that are based on what we consider to be sensitive information such as detailed financial information and sensitive medical conditions. We don’t use data segments to determine creditworthiness, for insurance underwriting or similar purposes. At Spotfront, we think it is important to provide this transparency to help you have a better idea of which segments might be collected by us, so that you can make informed decisions as an internet user.

Information You Provide to Us

We receive and store any information you enter on the Site or through the Services or provide to us in any other way. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our features. The PII you provide through the Site or Services is used for such purposes as responding to your requests for use of the PromoteIQ Service Platform, customizing the content you see, communicating with you about our products, and marketing our Services and those of our partners to you.

From time to time, we may ask that you provide your first name, last name, company name, email address, and information about whether you are a retailer, brand, vendor, or other. You may also choose to provide any additional information that you’d like to share about yourself.

Further information may be required if you choose to purchase the PromoteIQ Service Platform, such as credit card and billing information.

E-mail Communications

If you contact us via e-mail through the Site, we may retain a record of your contact information and any information you provide us in your message to respond to you. We may receive a confirmation when you open an e-mail from Spotfront.

We may also send e-mails with service updates, news, or promotions. If you do not want to receive marketing e-mail from us, please contact us at or click the unsubscribe button on the applicable e-mail. If you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Site and Services.

Information From Other Sources

To improve our Services, we may receive behavioral, contextual, and demographic information about you from other sources and add it to our account information or other information we have about you. Like the information you provide to us, we do not share this information with anyone except authorized third parties in connection with providing you with our Services and we will not use this data to identify or locate you personally.


Cookies are alphanumeric identifiers transferred to your computer’s hard drive through your web browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. Like most internet sites, Spotfront uses cookies to enhance a user’s experience on the internet. Spotfront may set cookies directly on internet users that receive ads sent through Spotfront or rely on partners to set cookies on our behalf. These cookies do not collect PII, and we do not combine information collected through cookies with other PII to tell us who you are or what your name or e-mail address is.

Most browsers allow you to prevent the browser from accepting new cookies, to be notified when you receive a new cookie, or to disable cookies. If you disable cookies, you may not be able to take advantage of some of Spotfront’s features. To disable cookies set by Spotfront or Spotfront partners, simply contact us at and we will provide you with an opt-out.

Consumer Choice and Access

Since Spotfront does not collect PII from internet users who receive advertisements from our advertisers, we do not maintain a process for an individual internet user to review and/or request changes to his or her PII.  If you would like to make such a request, please send us an email to, and we will make reasonable efforts to comply.

Sharing of Information by Spotfront

We neither rent nor sell your PII to anyone. Unless otherwise set forth in any additional agreements you enter into with Spotfront, we share your PII only as described below:

Business Partners

Spotfront may provide services or sell products jointly with business partners. We may share visitor and/or user information with those business partners, including information that is related to any joint transactions. We require our business partners to provide the same level of privacy protection that we do, and they do not have the right to share or use PII for any purpose other than for an authorized transaction. Spotfront shall be entitled to receive from such business partners a record of your interactions and transactions with them using the Services. Spotfront may share aggregated demographic information with business partners.


We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and services. Examples include billing, processing payments, providing marketing assistance, and providing customer service. Our agents subscribe to the same level of privacy protection as we do. Unless we tell you differently, Spotfront’s agents do not have any right to use the PII we share with them beyond what is necessary to assist us.

Financial Information

Financial and billing information collected through the Site and Services is used solely to bill for the Services. Spotfront may transmit this information to independent contractors who are bound to us by written confidentiality agreements. This billing information is not used by Spotfront for marketing or promotional purposes. Spotfront uses a third-party intermediary to manage credit card processing who may store, retain, and use the information provided solely for the purpose of credit card processing.

Promotional Offers

We may send offers to certain users on behalf of other businesses or provide our merchants with the opportunity to notify users directly of promotions by text messages or e-mail. If you do not wish to receive these offers, please e-mail us at

2. Additional Policies

Business Transfers

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Spotfront, or substantially all of its assets, were acquired, user information would be one of the assets that is reviewed and transferred. You acknowledge that such transfers may occur, and that any acquirer of Spotfront may continue to use your information, including your PII, as set forth in this policy.

Protection of Spotfront and Others

We may release information, including PII, when we in our sole discretion believe in good faith that release is necessary or appropriate to comply with the law, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of Spotfront, our employees, our users, or others.

With Your Consent

We may share your information, which may include PII, with certain third parties with your consent or at your direction, including if you provide us with the applicable information after we notify you that information will be shared in a particular manner.

Conditions of Use

Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of Washington state law.

International Visitors

For users outside the United States, please note that any data or PII you enter into the Services or Site will be transferred out of your country and into the United States. You consent to such transfer through your use of the Services and Site. You also warrant that you have the right to transfer such information outside your country and into the United States.

Use of Spotfront by Children

Spotfront is not intended for children. If you are under 18, you may use the Site and Services only with the supervision of your parent or guardian.

Third Party Sites

The Site and Services may permit you to link to other websites or services on the internet, and other websites or services may contain links to the Site or Services. These other websites and services are not under Spotfront’s control and Spotfront is not responsible for the privacy or security practices or the content of such websites or services.

Changes to this Privacy Policy

Spotfront may amend this Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes to our privacy policy, we will notify you by posting an announcement on our Site or such other method we reasonably deem appropriate.

Questions or Concerns

If you have any questions or concerns regarding privacy at Spotfront, please send us a detailed message to or to Spotfront, Inc. at 584 Broadway Suite 603, New York, NY 10012. Your privacy is important to us and we will make every effort to resolve your concerns.