Our Privacy Policy

Effective Date: May 20, 2020

Welcome! You have arrived at marlinconnections.net (the “Site”), provided by Marlin Connections (“Marlin” or “we,” “our” or “us”), or you are otherwise interacting with our services (together with the Site, the “Services”). We are committed to respecting and protecting your privacy.  It is important that you read and understand this Privacy Policy before using the Services.  

1. SCOPE

Except where otherwise stated, this Privacy Policy applies to the personal information (“Personal Information”) we collect through the Site. This Privacy Policy is intended to describe what information we collect about you, why we collect it, how we use it, and under what circumstances we may share it with third parties. To the extent we provide you different or additional privacy policies or notices in connection with the Services (e.g., at the point of our collection), those additional terms shall govern such data collection and use. In addition, please review the Site’s Terms of Use, which, in addition to this Privacy Policy, governs your use of the Site.  If you voluntarily provide your information in the course of participating with our Services or otherwise using or interacting with the Site, you consent to our Privacy Policy and Terms of Use, including our collection, use and sharing of your information and data, and other activities, as described in this Privacy Policy. Please note, unless otherwise stated, this Privacy Policy does not apply to the following:

• Any websites or Services that post separate online privacy policies;
• Data collection activities that occur outside the Site or Services;

2. INFORMATION WE COLLECT

We may obtain the categories of Personal Information described below through the Site, including from the following categories of sources.

a. Information You Provide to Us

On our Site or through our Services, we may ask you to provide us with or we may otherwise collect the following categories of Personal Information:

• Your contact information (such as first and last name, email address, and zip code);
• Information related to your employment (such as your job title, business address, employer, and industry);
• Information relating to your Internet activity (such as IP address, browsing actions, usage patterns, and device information), as more fully described below;
• Inferences about you, such as your preferences; and
• Other information you submit to us, such as through our “Contact Us” feature.
• We may also collect Personal Information when you:
• Sign up or request to be placed on our mailing, SMS/text and/or email marketing lists;
• Request or download information from us or through our Site;
• Contact us regarding a question or concern;
• Otherwise interact with us through the Site or Service.

Participation in the Site and Services is completely voluntary.  You are not required to provide all Personal Information identified in this Privacy Policy; however, please be advised that if you do not provide the Personal Information requested, we may be unable to provide some or all of the Services to you, and your ability to use the Site may be limited.

b. General Browsing As You Access and Use the Service 

In addition to any Personal Information or other information that you choose to submit to us via the Site or the Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site or the Services (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites or the Services.  To the extent we associate Usage Information with your Personal Information we collect directly from you on the Site or the Services, we will treat it as Personal Information unless we have disclosed otherwise.

This Usage Information may include:

• your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Site or the Services, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the URL that referred you to our Site or Services;
• the areas within our Site or Service that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• certain other Device data, including the time of day, among other information.

c. Use of Cookies and Other Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device. We use Tracking Technologies for a variety of purposes, including:

• To allow you to use and access our Site and Service;
• To prevent fraudulent activity and improved security functionality or to allow you to make use of other Site functionality;
• To assess the performance of the Site for analytic purposes or otherwise to improve our Services offered through the Site;
• To offer you enhanced functionality when accessing the Site, including identifying you when you sign‑in to our Site, keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
• To deliver ads and other content which may be of interest to you on our Site as well as third‑party sites, based on how you interact with the ads or other content on the Site.

Please be aware that any changes you make to cookie settings may render certain functions of our website inoperable or more difficult to use.

d. Information We Collect When You Interact with Third-Party Sites  

In addition, third parties may use Tracking Technologies in connection with our Sites, which may include the collection of information about your online activities over time and across third-party web sites or online services.  We may not control those Tracking Technologies, and we are not responsible for them.  For example, the Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application.  The use of this functionality may involve the third-party site providing information to us.  For example, we may provide links on the Site to facilitate you sending a communication from the Site or we may use third parties to facilitate you sending emails, or making Tweets or Facebook, Instagram, or Pinterest postings.  These third parties may retain any information used or provided in any such communications or activities, and these third parties’ practices are not subject to our Privacy Policy.  We may not control or have access to your communications sent through those third parties.  Further, when you use third-party sites or services, you are using their services and not our Services and the third parties, not Advantage, are responsible for their practices.  You should review the applicable third-party privacy policies before using such third-party tools on our Site.

e. Anonymized Information

We may create de-identified or anonymous data from Personal Information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means (“Anonymized Information”).  Our use of Anonymized Information is not subject to this Privacy Policy.

3. WHY WE COLLECT YOUR INFORMATION

We may use your Personal Information or Usage Information for the following purposes:

• Helping to establish and verify the identity of visitors to the Site or users of the Services;
• Providing email and mobile marketing messages, where you have signed up to receive them;
• Marketing our Services;
• Providing the Services;
• Improving the Site, including performing usage analytics and tailoring the Site to your preferences;
• Providing you with updates to the Site or Services and other important updates;
• Responding to your questions, inquiries, comments, complaints and instructions;
• Maintaining the security and integrity of our systems, including the Site; and
• Legal compliance, fraud prevention, and investigations.

4. HOW DO WE SHARE YOUR INFORMATION?

We may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy or any notice provided at the time your Personal Information is collected.

(a) Our Sponsors and Other Third Parties. We may share your Personal Information with third parties who sponsor the Services, or to other third parties, such as our clients, for their direct marketing purposes. We are not responsible for the privacy policies and practices of such third parties. If you are a California resident, please see the Your California Privacy Rights section for information on how to opt out.

(b) When You Request Information From Third Parties.  You may be presented with an option on our Site or through our Services to receive certain information and/or marketing offers directly from third parties, or to have us send certain information to third parties or give them access to it for the purpose of providing information to you.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties, and the disclosed information will also be subject to the privacy policies and practices of those third parties.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Sites or link to them from our Site or Services.  We are not responsible for the privacy policies and practices of such third parties; therefore, you should review carefully the privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(c) Third Parties Providing Services on Our Behalf.  We may use third-party service providers to perform certain services on behalf of us or the Site, such as (i) assisting with the Site operations, (ii) hosting the Site, (iii) designing and/or operating the Site’s features, (iv) tracking the Site’s activities and analytics, and (v) enabling us to send you special offers or perform other administrative services.  We may provide these service providers with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing.

(d) To Protect the Rights of Marlin and Others.  We may share Personal Information with governmental authorities when legally required to do so, and to cooperate with such authorities investigating claims of illegal activity such as (but not limited to) illegal transfer of copyrighted material, or user website postings or email messages that contain threats of violence. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Marlin or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) in other cases where we have reason to believe that disclosure is necessary to enforce compliance with our Terms of Use.  To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(e) Affiliates and Business Transfer.  Subject to applicable law, we may share your information, including your Device Identifiers and Personal Information, and Usage Information with our affiliated companies, subsidiaries, joint ventures, and other companies under our common control (“Affiliates”).  We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

5. THIRD-PARTY CONTENT AND LINKS TO OTHER SITES

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you.  In addition, the Site or Service may contain links or otherwise provide access to another website, mobile application, or Internet location that we do not control (collectively “Third-Party Sites”).  Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites.  We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.

6. ADS AND YOUR INFORMATION 

You may see certain ads on other websites because we participate in advertising networks administered by third parties.  These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests.  The information they collect includes information about your visits to our Site, such as the pages you have viewed.  This collection and ad targeting take place both on our Site and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our marketing efforts.

We may also use Tracking Technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests.  We and third-party service providers, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site.  To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here.  To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here.  If you would like more information about behavioral advertising practices, please visit www.aboutads.info.  To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices.  You may also click on the informational icon contained within each interest based ad.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data.  Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect.  The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices.  We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

7. YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to any California residents about whom we have collected Personal Information from any source, including through your interaction with the Site or the Services, or by communicating with us electronically, in paper correspondence, or in person. As a reminder, this Privacy Policy does not apply to the data practices of third parties, and requests should be submitted directly to such third parties.

a. Your Information

To review what information we collect, where we get it from, how we use it and how we share it, please visit the following sections of this Privacy Policy:

• Information We Collect – to review what information we collect and where we get it from.
• Why We Collect Your Information – to review how we use your Personal Information.
• How Do We Share Your Information? – to review who has access to your Personal Information.

We “sell,” as that term is defined in the California Consumer Privacy Act (“CCPA”), the following categories of Personal Information to our sponsors or other third parties:

• Your contact information (such as first and last name, email address, and zip code);
• Information related to your employment (such as your job title, business address, employer, and industry);
• And Inferences about you, such as your preferences.

Additionally, because some uses of third party services identified in the Ads and Your Information and Use of Cookies and Other Tracking Technologies sections may constitute a “sale” under the CCPA, we encourage you to exercise the choices available there from every browser that you use to access our Sites and the Services.

b. Your Rights Under California Law

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your Personal Information:

• Right to Know.  You have the right to request what Personal Information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete.  You have the right to request the deletion of your Personal Information that is collected or maintained by us.
• Right to Non-Discrimination.  You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
• Right to Opt Out of “Sale”. You have the right to direct us not to “sell” your Personal Information, as that term is defined in the CCPA.

You may also authorize someone to exercise the above rights on your behalf. When this individual submits a request, they will need to indicate on the webform or during the phone call that they are authorized to do so on your behalf, and supply us with evidence of this authorization; we will not fulfill a request submitted by a third party related to your Personal Information until we have received confirmation of your authorization for that individual to submit a request on your behalf.  If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests.  These rights are also subject to various exclusions and exceptions under applicable laws.  We will verify your identity by matching information you provide in your request with the information in our systems; and by requiring you to respond to an automated email sent to your email address upon submitting a request.

c. Exercising Your Rights

If you are a California resident and wish to exercise these rights, please reach us in one of the following ways:

• Interactive webform, accessible HERE.
• By calling us, toll-free, at 1 (888) 651-2032

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Marlin Connections
Attn: Legal Department
18100 Von Karman Avenue, Suite 900
Irvine, CA 92612

[email protected]

8. YOUR RIGHTS AND CHOICES ABOUT THE INFORMATION WE COLLECT

Individuals in certain jurisdictions have certain rights under applicable data protection law.  Rights specific to California residents are described in Section 7. Subject to applicable law, you may have the right to request access to, modification or correction of, or deletion of certain of your Personal Information that we maintain, and how that information has been used or disclosed. In addition, you may also have the right to direct Marlin not to sell certain of your Personal Information that we have collected or will collect about you.

To exercise your rights, you may contact us as at [email protected] or at the mailing address noted below. As permitted by law, certain data elements may not be subject to access, modification, correction, and/or deletion.  Furthermore, where permissible, we may charge for this service.  We will respond to reasonable requests as soon as practicable and as required by law.  To protect your privacy and security, we may take steps to verify your identity in order to respond to your request.

9. PROTECTING THE PRIVACY OF MINORS

We recognize the importance of children’s safety and privacy. This is a general audience Site and is not designed to attract children and are not intended for use by any children under the age of 16. We do not knowingly request or collect Personal Information from children under the age of 16.  If you are under 16 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.  In the event that we become aware that we have collected Personal Information from a child under the age of 16, we will take steps to dispose of that information as permitted by law and in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 16 has provided us with Personal Information without your consent, please contact us at [email protected].

10. DO NOT TRACK DISCLOSURES

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals).  Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

11. VISITORS TO THE SITE FROM OUTSIDE OF THE UNITED STATES

Our Site and Services are operated in the United States and intended for users located in the United States.  If you are located outside of the United States, please be advised that all of the information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States, and that this is necessary to provide you with the requested information and services and/or to perform any requested transaction.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.  By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.  For more information about our policies regarding cross-border transfers of Personal Information, you may contact us at [email protected] or at the mailing address noted in the “Your Rights and Choices About the Information We Collect” section of this Privacy Policy.

12. SECURITY

We implement technical and organizational safeguards designed to help protect and secure your Personal Information. We have taken steps to ensure that only our personnel and contractors who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.  Please note, however, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site.

13. UPDATES TO PRIVACY POLICY

We may update this Privacy Policy from time to time.  The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.

14. CONTACT US

For more information about our privacy practices, or if you have questions or concerns, please contact us by e-mail at [email protected] or by mail using the details provided below:

Marlin Connections
Attn: Legal Department
18100 Von Karman Avenue, Suite 900
Irvine, CA 92612