This policy explains how Assemble Digital Ltd ("Assemble," "we," "us" or "our") collects, uses and shares information about you to customize your experiences on our digital properties and elsewhere and for other purposes relating to our business. These activities are powered by data collected, used and shared on Assemble' website located at assemble.me and Assemble Apps, and also on Microsites, Third-Party Sites and elsewhere, as described herein (wherever you encounter Assemble functionality collectively, the "Assemble Service").
Where You May Encounter the Assemble Service
We may collect information about you and your activities by way of:
- A website at assemble.me, Assemble-branded device and platform-specific applications ("Apps") and Notifications and other direct communications between us or a Assemble Partner and you.
- Standalone web destinations styled and configured by or on behalf of Assemble Partners using Assemble tools and offering Assemble functionality. Websites are hosted by us and contain Assemble attribution.
- Third-party properties incorporating Assemble functionality, identified by Assemble attribution or that contain Assemble pixels for tracking purposes ("Third-Party Sites"). Third-Party Sites may include blogs, social media or Product-specific, industry-focused or general interest media properties or any destination with advertisements incorporating Assemble functionality.
- Links placed by Assemble Partners in social media, advertisements, trailers / videos and other marketing activities which, when clicked, direct you to a specific webpage at assemble.me or a similar App destination, a Microsite, a Third-Party Site or directly to a retailer or other web destination via a redirect through Assemble ("Inbound Links").
What Personal Information Do We Collect?
Personal Information ("PI") is information that can be used to identify an individual, including name, postal address, mobile phone number or e-mail address. You provide us with PI when you create a Assemble Account and/or when you enter or edit information in your Account profile ("Profile"). If you create an Account through a social media service such as Facebook Connect or subsequently associate your Account with one or more social media or other accounts, we may receive your user name(s), e-mail address and/or other information depending on your account settings with the relevant Associated Service. We may also receive certain PI about others when you create an Account or otherwise interact with the Assemble Service, including names and email addresses of your contacts or friends.
What Activity, Demographic & Technical Information Do We Collect?
How We Use Information
- Responding to your requests to provide you with Notifications and disseminating other direct communications to you.
- Customizing the Assemble Service according to your expected interests, location or other preferences.
- Delivering advertisements to you via the Assemble Service or elsewhere, including on behalf of third-parties.
- Making recommendations to third-parties regarding marketing tactics and other strategic or operational decisions.
- Analyzing our audience behavior and usage patterns to help isolate and analyze service issues, improve the accuracy of our data and more generally enhance the Assemble Service for you and users more generally.
- For purposes as disclosed at the point of collection.
How We Share Information
We may share Information with certain third parties in the following ways:
- Processors and Service Providers: We may disclose Information to our contractors and certain other vendors or suppliers who process data on our behalf or assist us in the day to day operation of our services, including analytics vendors, e-mail and text messaging service providers and third-parties that help us manage and use Information collected via cookies, web beacons and similar technologies, including for use in interest-based advertising.
- Assemble Partners: We may disclose Information to the parties responsible for the deployments of Assemble functionality giving rise to such Information ("Assemble Partners"). Please note that the relevant Assemble Partner with respect to Assemble functionality on a given property may not be the owner or operator of such property. Information may be disclosed to Assemble Partners when collected:
- On Microsites.
- On Third-Party Sites.
- From Inbound Links and at the destinations to which you are directed when you click such links.
- On Themed Lists created by such Assemble Partners.
- From Direct Messages sent on behalf of such Assemble Partners.
- Assemble Partners may include filmed content studios and distributors, as well as a broad range of other entities promoting various Products and services.
- We provide Information to Assemble Partners to help them better understand the impact of their marketing and other efforts as well as their users' interests and preferences so they can customize their services for you, improve the general utility of their offerings and develop their own direct relationships with you. Assemble Partners may use Information to directly market to you, or they may further share your Information.
- Associated Services: You may instruct us to share Information about you and your activities on the Assemble Service with Associated Services and other of their users.
- Data and Advertising Customers: Because we want to help Assemble Partners and other third-parties better understand how users in general interact with Assemble functionality and with various Products, we may remove certain data elements, such as device ID and name, e-mail address or other Information as previously defined and publish or share the resulting aggregated data with a variety of third-parties. We may also provide Information to Assemble Partners and other third-parties for use in interest-based advertising.
- Transfer of Assets: We may transfer Information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. We may also use and disclose your Information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties.
- Your Consent: We may share Information with third-parties and others when you give us your consent.
Who Else Might Have Access to Your Information via the Assemble Service
As you interact with the Assemble Service, certain other third-parties may directly collect Information about you and your activities and may combine such information with other information they have associated with you. Please note that we are not responsible for the privacy practices of any such third-parties and we recommend you read their privacy policies to learn how they use your Information. Such third-parties may include:
- Third-Party Sites: Third-Party Sites may directly monitor your activity on their properties or provide access for others to do so.
- Assemble Partners: We enable Assemble Partners to directly place their own cookies, web beacons and similar technologies in their deployments of Assemble functionality via Microsites and on Third-Party Sites, including, those they do not own or operate, as well as on webpages at assemble.me or similar App destinations reached via Inbound Links they deploy.
- Linked Sites: We may provide outbound links to retailers, advertisers or other web destinations (together with the locations where Inbound Links are placed, "Linked Sites"). Linked Sites may directly monitor your activity on their properties or provide access for others to do so.
- Other service providers: We may provide you with direct access to functionality from other third-parties, including: social media services such as Facebook, Twitter and others; trailer providers such as YouTube and others; and advertisers and advertising service providers. These third-parties may be able to see Information about you and your activities on the Assemble Service, even if you do not interact with them. We may also utilize Google Analytics and other similar services for certain activity monitoring and reporting which similarly access non-personally identifiable information. To opt out of Google Analytics collection and use your information, please go here.
Cookies, Web Beacons and Similar Technologies
We use a variety of technologies to learn more about how you use the Internet and the Assemble Service as described below. We may use all of these technologies, or other similar technologies across the Assemble Service.
- A web beacon, also called a single-pixel (1x1), clear GIF or pixel tag, is an electronic image embedded in a webpage or HTML-based e-mail. Web beacons can recognize certain types of information on your computer, such as a cookie number, time and date of a page view and the webpage where the beacon is placed. While you may not decline web beacons, you may render some web beacons unusable by rejecting their associated cookies. But, like we said, if you disable the cookies associated with a beacon, some Assemble functionality may not work properly.
- Other similar technologies. We and our service providers, advertisers and other third-parties may use other kinds of technology such as local storage objects, including "flash cookies," authentication tokens and HTML5 local storage. Like cookies, these technologies are stored on your computer, albeit in different parts of your device, and perform similar functions. They can also be used to store certain information about your preferences. Your Internet browser may allow you to disable HTML5 or delete information contained in HTML5 local storage by changing your browser settings. Please note that disabling these technologies may interfere with the performance and features of the Assemble Service.
Interest-Based Advertising and Choices
Certain third-parties may engage in interest-based advertising ("IBA") via the Assemble Service. IBA involves the collection of web viewing and application use data across this website and/or application and other non-affiliated websites and apps over time and across browsers and devices, and the use of such data, often along with other data, to infer consumer interests. These inferred interests are used to provide relevant advertising to you across various browsers and devices attributed to you. If you would like to learn more about interest-based advertising, or to opt-out of this practice from third-party companies participating in the Digital Advertising Alliance ("DAA") Program for this browser, please visit the DAA Consumer Choice Page here. To learn more about IBA on this device, download the AppChoices application, available for iOS and Android. To learn how to opt-out of having your information collected in mobile apps on this mobile device by third-party companies participating in AppChoices, please click here.
Additionally, Assemble adheres to the DAA's Self-Regulatory Principles. We also collect information about your activity across non-affiliated websites and applications, over time and across devices for IBA purposes. To opt-out of our collection, use and transfer of information about your mobile app usage history on this mobile device, you can choose to limit that activity through your mobile device's platform controls, such as "limit ad tracking."
If you delete cookies, reset your device identifier or use another browser or device, you may need to repeat your choices. If you opt out, you will still receive ads, but these ads may be less relevant to you. If you elect to opt out, we may still collect data for other purposes including analytics, reporting, content personalization and other business purposes.
To disable our collection of precise location information from your mobile device, you can access your mobile device settings and choose to limit that collection.
If you are a California resident, you have the right to receive: (i) information identifying any third-party company(ies) to whom we may have disclosed, within the past year, PI for that company's direct marketing purposes; and (ii) a description of the categories of PI disclosed. To obtain such information, please e-mail your request to privacy@Assemble.me.
How We Protect Your Information
Assemble takes reasonable administrative and electronic measures to help safeguard and protect your PI from accidental loss or unauthorized access, disclosure or use. Although Assemble strives to protect your PI, no security method can be guaranteed to protect information, and we therefore expressly disclaim responsibility and/or liability for the loss, theft, destruction or inadvertent disclosure of your PI.
How You Can Access or Correct Your Information
If you are an Account User, you can log-in to your Account to see what PI you have provided to us in your Profile. You may update such information at any time. If you have questions about your information, please e-mail us at firstname.lastname@example.org
Treatment of PI on Account Termination
Unless your Account is terminated, we will continue collecting, using and sharing your PI and other information as described herein. It is Assemble policy to retain your PI for one year after your Account has been terminated. In accordance with the law, we may retain anonymous data perpetually.
How to Contact Us with Questions or Concerns
Assemble is based in New Zealand. Please be aware that information you provide to us or that we obtain as a result of your use of the Assemble Service may be processed and transferred to, and be subject to the laws of, New Zealand and the United States. The privacy and data protection laws in New Zealand may not be equivalent to similar laws in your country of residence. By using the Assemble Service, or by providing us with your PI, you consent to the collection, transfer, storage and processing of information to and within New Zealand and the United States. If we detect IP addresses located in a country outside the United States or New Zealand, we reserve the right to deny access to any and all of our services.