The European Union General Data Protection Regulation (GDPR) Privacy Policy

Effective May 25, 2018

This Pape Ventures Privacy Policy (“Policy”) outlines the information that Pape Ventures, Inc. (“Pape Ventures”, “Ad Sales Genius”, “Subscription Genius”, “we”, “us”, or “our”) gathers, how we use that information, and the options you have to access, correct, or delete such information.

PAPE VENTURES PROMISE

We commit to communicate transparently, provide security, and protect the privacy of data in our systems.

We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.

POLICY APPLICATION:

This Policy applies to Pape Ventures’ collection, use and disclosure of the information of the following categories of individuals:

Website Visitors: Individuals who visit our Websites and who may option to provide an email address to receive communications from Pape Ventures. For the purposes of this Policy, “Websites” shall refer collectively to www.papeventures.com, www.adsalesgenius.com, and www.subscriptiongenius.com as well as any other websites Pape Ventures owns and that link to this Policy. For clarity, “Websites” does not include any sites owned or operations by our Customers. Customers: Those who register on their own or on behalf of an entity or organization to use any of the Pape Ventures Services (as defined below), including administrators on a Customer account. For the purposes of this Policy, “Services” shall refer to all network service solutions marketed for subscription at www.papeventures.com, www.adsalesgenius.com, and www.subscriptiongenius.com, including when Services are sold by an authorized partner or reseller. End Users: Individuals who visit our Customers’ websites and whose information we process in order to provide the Services to our Customers pursuant to our agreements with them.

This Policy does not apply to our Customers’ websites, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for an ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Services by End Users with whom our Customers interact.

Pape Ventures Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen. Pape Ventures does not knowingly collect personally identifiable information from any person under the age of eighteen.

2. INFORMATION WE COLLECT: Website Visitors:

Name, email address, and other contact information. We ask for and-at your option-collect personal information from you when you submit web forms on our Websites, including opportunities to sign up for and agree to receive mail communications from us. We may also ask you to submit such personal information if you choose to use interactive features of the Websites, including participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.

Log Files. Just as when you visit and interact with most websites and services delivered Bia the Internet, when you visit our Websites, including any forums, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.

Cookies and Other Tracking Technologies. We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites and assisting us in our marketing efforts. You an control how websites use cookies by configuring your browser’s privacy settings (please refer to your browser’s help function to learn more about cookie controls). Note that if you disable cookies entirely, Pape Ventures Websites may not function properly. We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your browsing activities and interests. If you wish not to have this information used for the purpose of servicing you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here).

Interactive Areas. The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). If you choose to participate in any of these Interactive Areas, please be aware any information you post in an Interactive Area might be read, collected, and used by others who access it. If you wish to remove your personal information from any of our Interactive areas, please see the section below entitled, Your Data Rights.

Customers:

Customer Account Information. When you register for a Pape Ventures account, we collect your e-mail address. We will also ask you to enter your website domain in order to participate in the Services. We refer to this information as “Customer Account Information” for the purposes of this Policy. Customer Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

Payment Information. You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address, although we do not store full credit card numbers or personal account numbers.

End Users:

Pape Ventures provides subscription management and Customer Relationship Management (CRM) services that our Customers use to manage print and digital publications, and advertising among other services, including a reverse proxy, pass-through security service, and a content distribution network. Because Pape Ventures is a reverse proxy, our IP addresses may appear in WHOIS and DNS records for websites using our Services. We are a conduit for information controlled by others. It is our Customers and their users who are responsible for the content transmitted across our network (e.g., images, written content, graphics, etc.)

We collect End Users’ information when they use our Customers’ websites, web applications, and APIs. This information may include but is not limited to IP addresses, system configuration information, and other information about traffic to and from Customers’ websites (collectively, “Log Data”). We collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data can help us to detect new threats, identify malicious third parties, and provide more robust security protection for our Customers.

Legal Basis for Processing (EEA only):

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Pape Ventures Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, Pape Ventures will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacyquestions@papeventures.com.

3. HOW WE USE INFORMATION WE COLLECT

Pape Ventures only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we collect (including personal information, to the extent applicable) to:

  • provide, operate, maintain, improve, and promote the Website and Services;
  • enable you to access and use the Website and Services;
  • process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
  • send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. See Section 8 below for information on managing your communication preferences.
  • process and deliver contest or sweepstakes entries and rewards;
  • monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
  • comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  • personalize the Websites and Services, including by providing features or content that match your interests and preferences; and
  • process for other purposes for which we obtain your consent.

Information from Third Party Services. We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on a Pape Ventures sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.

4. INFORMATION SHARING

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us deliver customer support, process credit card payments, manage and contact our existing Customers as well as sales leads, provide marketing support, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations, including our obligations under the EU-US and Swiss-US Privacy Shield frameworks described in Section 6, below.

Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

  • Within the Pape Ventures Group;
  • With our resellers and other sales partners who may help us distribute the Services to Customers;
  • With an app developer when you install an app from our integrations or utilize the API;
  • In the event of a merger, sale, change in control, or reorganization of all our part of our business;
  • When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
  • Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or
  • as you may otherwise consent from time to time.
5. DATA AGGREGATION

Pape Ventures may aggregate data we acquire about our Customers and their End Users, including the Log Data described above. For example, we may assemble data to determine how Web crawlers index the Internet and whether they are engaged in malicious activity or to compile web traffic reports and statistics. Non-personally identifiable, aggregated data may be shared with third parties.

6. INTERNATIONAL INFORMATION TRANSFERS

Pape Ventures is a U.S.-based company. We primarily store your information in the United States. To facilitate our international operations, we may transfer and access such information from around the world, including from other countries in which the Pape Ventures Group has customers for the purposes described in this Policy.

Whenever Pape Ventures shares personal information originating in the EEA or Switzerland with a Pape Ventures entity outside the EEA or Switzerland, it will do so on the basis of the EU standard contractual clauses or the Privacy Shield Frameworks detailed in this section.

If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we may operate.

Pape Ventures is self-certified under both the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA and Switzerland to the United States, respectively. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. For more information on the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website at: https://www.privacyshield.gov/welcome.

7. DATA SUBJECT RIGHTS

Attendees, Website Visitors, and Customers: You have the right to access, correct, update, export, or delete your personal information. You may email us at SAR@papeventures.com with any such subject access requests (“SAR”), and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at papeventures.com and selecting the appropriate product or service.

Resolver Users: We do not retain any personally identifiable information about Resolver Users that would be subject to the data subject rights described above.

End Users: Pape Ventures has no direct relationship with End Users. Even where “Pape Ventures” may be indicated as the authoritative name server for a domain, unless Pape Ventures is the owner of that domain, we have no control over a domain’s content. Accordingly, we rely upon our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that we access, correct, update, or delete their information, or no longer wishes to be contacted by one of our Customers that use our Services, we will direct that End User to contact the Customer website(s) with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their website users.

For any SAR, we will need to verify a requestor is inquiring about their own information before we can assist. Where a SAR may implicate the personal data of another individual, we must balance the request against the risk of violating another person’s privacy rights. We will comply with SARs to the extent required by applicable law or the US-Swiss or US-EU Privacy Shield. In the EU, you also have the right to lodge a complaint with a supervisory authority.

8. COMMUNICATION PREFERENCES

You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the bottom of such emails, through your account settings if you have a Pape Ventures account, or you may send a request to unsubscribe@papeventures.com.

9. DATA SECURITY, DATA INTEGRITY, AND ACCESS:

We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at privacyquestions@papeventures.com.

10. EMAIL INTEGRATIONS AND GOOGLE

We integrate the receiving of email through a third party called "context.io". Their website is https://context.io/ and their privacy policy URL is https://returnpath.com/privacy-policy/. For sending of email, we collect the necessary account credentials from you in order to facilitate sending. With the exception of the context.io email integration we do not do not share any of your information with any third parties outside of your own company. We do not alter or remove email from your inbox. If you have sending enabled, we do allow for you to be able to send email through our system.

11. NOTIFICATION OF CHANGES

If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.

12. BUSINESS TRANSACTIONS

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.

13. ENGLISH LANGUAGE CONTROLS

Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

14. CONTACT INFORMATION Pape Ventures, Inc.

Attention: Data Protection Officer
 PO BOX 60367
 NASHVILLE, TN 37206

 privacyquestions@papeventures.com