System1 Privacy Policy

Last modified: May 15, 2018

Introduction

System1 LLC respects your privacy and we are committed to protecting it through our compliance with this policy.  This policy also applies to our subsidiaries Infospace Holdings LLC and Qool Media Holdings LLC.

Our services include our websites and applications that link to this privacy policy. This policy describes the types of information we may collect from you or that you may provide when you use our services and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our services. By accessing or using our services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

EU-US Privacy Shield and Swiss-US Privacy Shield.  

System1 LLC, and certain of its controlled US affiliates, Infospace Holdings LLC and Qool Media Holdings LLC, comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. System1 has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit  https://www.privacyshield.gov/

System1 is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Children Under the Age of 13

Our services are not intended for children under 13 years of age. No one under age 13 may provide any information to or through our services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through our services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at:

Attn: Privacy Officer

1501 Main Street

Suite 201

Venice, CA 90291

privacy@system1.com

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our services, including information:

We collect this information:

Information You Provide to Us.  The information we collect through our services may include:

Information We Collect Through Automatic Data Collection Technologies.  As you use our services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include:

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

We may also disclose your personal information:

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Accessing and Correcting Your Information

We desire to keep you in control of the personal information you provide to us. Accordingly, you can review, correct, change, or remove the personal registration information you provide to us and that we control. To choose not to receive future communications from us, please Contact us.

You may also send us an email at privacy@system1.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the services.

Dispute Resolution

In compliance with the EU-US and Swiss-US Privacy Shield Principles, System1 commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact System1 at: privacy@system1.com

System1 has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolutions procedures have been exhausted.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will let you know through a notice in our services. The date the privacy policy was last revised is found at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Attn: Privacy Officer

1501 Main Street

Suite 201

Venice, CA 90291

privacy@system1.com