Last Updated: July 9, 2018
Effective Date: May 25, 2018

Your privacy is important to us, and we have prepared this Privacy Policy to explain how we collect, use, and protect your information when you use any of our websites, including www.fuelx.com, (collectively, “our Website”) or interact with our advertising services (collectively, “our Services”), and to illustrate your choices for managing your information preferences. This includes your rights with regard to your personal data in accordance with the EU General Data Protection Regulation (hereinafter “GDPR”).

Personal data in this regard means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

By using our Services, you acknowledge the terms of this Privacy Policy. This Privacy Policy applies to all users of our Services and is incorporated in our Terms and Conditions of Use.

Information We Collect On Our Website.

Information You Provide Us. When you register on our Website, request information, or make a purchase from us, you provide us with information about you such as your name, username, password, email address, and phone number. When you make a purchase from us, we will collect your payment card information, but we do not store or process this information beyond providing it to our payment card processor.

(b) Information We Collect from Your Use of Our Website. We collect information on your use of our Website to help us understand how users use our Website and to improve our Services. For example, we record the type of web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to our Website.

(c) Cookies and Other Tracking Technologies. We use cookies (a small file containing a string of characters that uniquely identifies your Web browser) and other technologies to improve the quality of our Website. You can change your web browser settings to not accept cookies, but doing so may impact your experience with our Website. Some of our service providers may use cookies and other tracking technologies in connection with the services they perform on our behalf and may track users over time and across websites.

Our Website and Services employ the following cookies:

Cookie Name Owner Function Type
FXUUID FuelX FuelX User ID Temporary
FXNDID FuelX FuelX User ID Temporary
FXUUID_L FuelX FuelX User ID Temporary
FXUUID_P FuelX FuelX User ID Temporary
FXNDID_L FuelX FuelX User ID Temporary
FXNDID_P FuelX FuelX User ID Temporary
FXEXVal FuelX Exclusion flag Temporary
fxuuid_p_v FuelX Exclusion Flag Temporary
EXNDID FuelX Exclusion Flag  User ID Temporary
bid FuelX Client ID Temporary
fx_loc FuelX Encoded User info string Temporary
fx_brv FuelX Encoded User Info string Temporary
fvc FuelX Attribution Flag Temporary
gid FuelX Google User ID Temporary
fxuuid_v FuelX FuelX User ID Temporary
fxndid_v FuelX FuelX User ID Temporary
%%bid%% FuelX Client ID Macro Temporary

Information We Collect Through Our Advertising Services.

(a) Advertising Information. We collect and store information from our partners, including ad networks and publishers, and Clients in order to display ads relevant to you. This information includes persistent device identifiers, device information, geo-location information, IP address, gender, demographic information, and behavioral and interest information (“Advertising Information”). Please see Section 4 for choices you have regarding the collection and use of this information.

(b) Information from Other Sources. We collect information about actions taken on our ad partners properties to track the effectiveness of our ad placements. We may supplement the information we collect and the segments we create from it with information obtained from third parties, such as demographic, behavioral, and interest information, in order to improve the relevance of products, services, and advertisements offered on or through our Services

3. How We Use and Share Information We Collect.

(a) Contract Information. We will use the information you have provided when registering on our Website, requesting information, or making a purchase from us as described above under section 1 (a) for the purpose of performing our contractual obligations, to respond to requests for information or a service demonstration, or for other preparatory measures with regard to such contract upon request in accordance with Art. 6 (1) b GDPR. Without this information, we are unable to accept any contractual obligations in accordance with your request.

(b) FuelX Website Information. We use the information collected on our Website, to notify you of new products or services,  to respond to general inquiries and/or comments, to send service notifications, to customize the content you see, to improve our Website, to conduct research, and to solicit your feedback and input about our Website. We do not rent, sell, or share this information with third parties, except as set forth in this policy. This use of your personal data is based on our legitimate interests to improve our Website and Services and provide additional information based on your interests in accordance with Art. 6 (1) f GDPR.

(c) Ad Partner Website Information. We use session related data collected from our advertising partners’ websites and apps to measure the effectiveness of their ad spend and our services in accordance with Art. 6 (1) f GDPR. This in turn is used to customize the content you see and to improve the placements of their ads. Advertising Partners are able to see session related data about their customers similar to what they would see in their own web analytic platforms. Information about user behavior shared with our advertising partners is limited to only that behavior as it relates to that advertising partner. We do not rent, sell, or share this information with third parties, except as set forth in this policy.

(d) Advertising Information. We use information from our Ad Network Partners (eg: Google’s AdX) to determine your preferences and general location, which in turn enables us to make our marketing and advertising services more useful and relevant to you in accordance with Art. 6 (1) f GDPR. This includes making product recommendations to you in the form of advertisements sent by our Clients or by us on our Clients’ behalf to your computer, mobile device, or other connected device. Please see Section 4 for choices and rights you have regarding the collection and use of this information. Please also refer to each of our Ad Network’s websites to ensure your information is being shared appropriately and you’re aware of their policies and procedures for exclusion as well as our own.

Ad Network Privacy Policy
Google (Ad Exchange, Double Click, etc.) https://policies.google.com/?hl=en
Facebook https://www.facebook.com/privacy/explanation
Triple Lift https://triplelift.com/privacy/
Oracle Marketing Cloud https://www.oracle.com/legal/privacy/privacy-policy.html
Oath (fka: Brightroll) https://policies.oath.com/in/en/oath/privacy/index.html
LinkedIn https://www.linkedin.com/legal/privacy-policy
Pinterest https://policy.pinterest.com/en/privacy-policy

(e) Service Providers. We use service providers to provide certain services to us, such as credit card processing, analytics tools, DNS providers, data management services, Web hosting, and Web development. We provide our service providers with only the information necessary for them to perform these services for the purpose of performance of our contractual obligations or for measures in preparation for such a contract with you upon request in accordance with Art. 6 (1) b GDPR.

(f) Analytics Information. We may use and disclose to third parties information regarding the usage of their Website (e.g., number of visits, page views, number of registered members who reside in a particular geographic location) as a result of our advertising services (see Section 3. (c) above) for analytical purposes. Such information does not identify you individually.

(g) Affiliates; Change of Control. We may share information we collect with our affiliates. In the event that FuelX is merged, sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer information we collect in connection with the negotiation and/or conclusion of such a transaction on the basis of our prevailing legitimate interests in participating in cooperating with our affiliates or being subject to such transactions ín accordance with Art. 6 (1) f GDPR.

(h) Other Disclosures. We may disclose information about you to third parties if (a) that disclosure is necessary to comply with any applicable law, regulation, legal process, or governmental request (Art. 6 (1) GDPR), (b) to enforce our agreements, policies, and terms of service (Art. 6 (1) f GDPR), (c) to protect the security or integrity of our Services (Art. 6 (1) lit. f GDPR), (d) to protect the property, rights, and safety of us, our customers, or the public from harm or illegal activities (Art. 6 (1) f GDPR), (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person (Art. 6 (1) d GDPR), or (f) to investigate and defend ourselves against any third-party claims or allegations (Art. 6 para. 1 lit. f GDPR).

4. Choices You Have with Your Information.

(a) You may review, correct, update, or change your account registration information by accessing your settings in your FuelX user profile or by contacting us at legal@fuelx.com.

(b) With regard to any personal data processed by us in accordance with this privacy policy, you are by law entitled to:

  • Access your personal data processed by us,
  • Have your personal data rectified or erased (“right to be forgotten”),
  • Have the processing of your personal data restricted, effectively barring further access,
  • Receive a copy of your personal data (“right to data portability”).

(c) In addition, you may object to any processing of your personal data – including its use for profiling purposes – where such processing is legally based on our prevailing legitimate interests in accordance with Art. 6 (1) f GDPR by contacting us at legal@fuelx.com or through any other contact provided under section 10 below and providing personal reasons why such processing should be discontinued. We will comply with your objection unless we can demonstrate prevailing legitimate interests in continuing to process your personal data, including the necessity of using your personal data for protecting legal claims or defending against such.

Without regard to the foregoing, you may object to any processing of your personal data for advertising purposes without having to provide any reasons by contacting us at legal@fuelx.com or through any other contact provided below under section 10 below.

(d) You have the right to lodge a complaint with a supervisory authority with regard to our processing of your personal data.

(e) If you choose to object to our using your personal data for the purposes of serving you personalized advertisements as specified above, please note that this does not mean that you will not see ads or recommendations from us. Rather, you will see a generic ad or recommendation in place of personalized content because no data related to you individually will have been used to tailor the ad. When you opt-out, we place an opt-out cookie on your device. If you delete your cookies or use a different device or Internet browser after opting out, you will need to renew your opt-out. Please note that this opt-out will not prevent other companies from serving you personalized content.

(f) You may opt out of receiving promotional email communications from us by using the unsubscribe link included within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive administrative messages from us regarding our Services.

5. Children’s Privacy Statement.

>Our Services are not intended for children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If we learn that we have collected the personal information from a child under the age of 16, we will take steps to delete the information. If you are aware that a child under 16 has provided us with personal information, please contact us at legal@fuelx.com.

6. Do Not Track.

Some web browsers incorporate a “Do Not Track” (DNT) feature. Because there is not yet an accepted standard for how to respond to a DNT signal, our Website does not currently respond to such signals. You may prevent the use of cookies and/or object to any processing of your personal advertising purposes as described above in sections 3 and 4 of this privacy policy respectively.

7. Processing in the United States.

Please be aware that personal information may be transferred to and maintained on, servers or databases located outside your state, province, country, or other jurisdiction where the privacy laws may not be the same as those in your location. If you are located outside of the United States, please be advised that we transfer all information to the United States for storage and processing, and your consent to this Privacy Policy represents your consent to this transfer, storage, and processing.

8. Changes to this Privacy Policy.

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through our Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy.

9. Contacting Us.

If you have questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at:

FuelX Inc.
Attn: Legal Affairs – Privacy
1400 Fashion Island Blvd, Suite 180
San Mateo, CA  94404
legal@fuelx.com

You can also contact our Data Protection Officer (DPO) with any questions concerning use of your Personal Data at:

FuelX Inc.
Attn: Dan Haarmann, DPO
1400 Fashion Island Blvd, Suite 180
San Mateo, CA  94404
DPO@fuelx.com

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