Privacy Policy

PROGRAMMATIC MECHANICS & PONTIAC INTELLIGENCE PRIVACY POLICY

Last Effective Date: May 20, 2022

INTRODUCTION

Welcome to Programmatic Mechanics. This Privacy Policy explains how Programmatic Mechanics LLC and its subsidiaries, including Pontiac Intelligence LLC (collectively “PM”; “we”; “us”; or “our”) collects and processes information through our website at http://progmechs.com/ (“Website”), through our self-service advertising platform (“Pontiac”) and https://pontiac.media and via our products and services that provide advertising to consumers through third party platforms (“Products”). The Website, Pontiac and Products are collectively referred to as the “Service”. Please read this Privacy Policy carefully to understand our policies and practices regarding such information. If you do not agree with our policies and practices, you should not use the Service. By accessing or using this Service, you agree to this Privacy Policy.

OVERVIEW

Our Website is primarily an informational website.
Through Pontiac, you may choose to target advertising to online consumers.
Through our Products, we may buy and deliver online advertising on your behalf to consumers that are delivered through third party platforms not under our control.
Through our Products, we may also sell advertising on behalf of publishers to advertisers through third party platforms not under our control.
You can exercise certain rights regarding your information as described in the YOUR RIGHTS, CHOICES AND OPT OUT section below. Users in certain jurisdictions, such as California, the European Union and the United Kingdom, have specific rights which are set forth below.

INFORMATION COLLECTION

Our Service collects information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). PM collects the following categories of personal information and has collected the following categories of personal information from individuals within the last twelve (12) months, for the following categories of purposes and from the following categories of sources, and PM shares personal information with the following categories of third parties:

Category	Examples	Services	Purposes for Which Such Information Was Collected in the Preceding 12 Months or Will be Used	Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12 Months or will be Collected	Categories of Third Parties With Whom the Service Shares or Sells Personal Information
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers	Name, email address and similar information.	Website, Pontiac and Products	Website – To contact you directly for marketing purposes and manage operation of our Website. Pontiac/Products – To serve targeted advertising to you, analyze the performance of campaigns and report to our clients.	Website – Directly from you when voluntarily provided by you to us,including but not limited to emailing us directly. Pontiac/Products – Directly from you when interacting with ads. From third party providers and our clients.	Service providers (such as and backend technology providers), digital media platforms, and our clients in connection with reporting.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	General information about your interests and online activities.	Pontiac and Products	To inform our delivery of targeted advertising to you, analyze the performance of campaigns and report to our clients.	Directly from you when interacting with ads. From third party providers and our clients.	Service providers (such as and backend technology providers), digital media platforms, and our clients.
Biometric information	None	None	None	None	None
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement	Browsing history, search history, information on a user’s interaction with our Service, online identifiers (such as a cookie) and similar information.	Website, Pontiac and Products	To customize the Service provided to you, to analyze and improve use of the Service, develop analytics, for advertising, for testing and research purposes and as otherwise described below.	Directly from your device by observing your actions on our Service. From third parties who collect such information on our Service and elsewhere, such as analytics providers.	Service providers (such as and backend technology providers) and digital media platforms.
Geolocation data	General region or location.	Website, Pontiac and Products	To customize the Service provided to you, to analyze and improve use of the Service, develop analytics, for advertising, for testing and research purposes and as otherwise described below.	Directly from your device by observing your actions on our Service. From third parties who collect such information on our Service and elsewhere, such as analytics providers.	Service providers (such as and backend technology providers) and digital media platforms.
Professional or employment-related information	Employment history, resume/CV and similar background information.	Website	Evaluating you for employment with or provision of services to the Company.	Directly from you when you voluntarily provide such information to us.	Service providers (such as and backend technology providers).
Education information	Employment history, resume/CV and similar background information.	Website	Evaluating you for employment with or provision of services to the Company.	Directly from you when you voluntarily provide such information to us.	Service providers (such as and backend technology providers).
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Interest categories, demographics and online behaviors.	Website, Pontiac and Products	To customize the Service provided to you, to analyze and improve use of the Service, develop analytics, for advertising, for testing and research purposes and as otherwise described below.	Developed from other information collected under the Privacy Policy and by the Company	Service providers (such as and backend technology providers) and digital media platforms.

PAYMENT CARD DETAILS

If you make a payment through the Service, such as using our self-service advertising platform, your payment card details are provided directly to our service provider, Stripe. You may read their privacy policy at https://stripe.com/privacy to understand how they use your information. We only receive your contact information and the last 4 digits of your payment method for verification.

COOKIES

Browsing information is automatically collected through various means such as cookies and pixels through our Services or in our emails. “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, tags, etc.) through our Services to customize your visit, to analyze how you use our Services and for other purposes to make your visit more convenient, to manage your account or to enable us to enhance our Services. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge, but may be used to store your login credentials.

We may use Google Analytics, which is a web analytics service provided by Google, Inc. Google and similar services collect certain information relating to your use of our Services. Such services may use cookies to help us analyze how users use our Services. You can find out more about how Google uses data when you use our Services by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).

Based on your web browser, you may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the services. Further information on cookies is available at www.allaboutcookies.org.

HOW WE USE YOUR INFORMATION

We use information that we collect from you:

To deliver our Service and its contents to you;
To provide you with information on various products and services;
To market our Services to you;
To enable the delivery of online advertisements to you through Pontiac and Products;
To identify audience segments that are served advertisements through the Service;
To attribute whether advertisements delivered through Pontiac and Products result in an online action or decision;
To carry out our obligations and enforce our rights;
In any other way we may describe when we collect the information from you; and
For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose your information as described in this Privacy Policy or otherwise with your consent:

To contractors, service providers, and other third parties we use to support our business. However, such parties are only authorized by us to use the information for the benefit of us;
To certain clients of ours in connection with reporting on their advertisements;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by PM about our Service users is among the assets transferred;
To companies within the same corporate family as PM;
To comply with any court order, law, or legal process, including to respond to any lawful government or regulatory request;
To enforce or apply our policies or investigate fraud; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PM, our users, clients or others.

Website – In addition, we may disclose your information in order to provide you with information and services you have requested, and to improve our Website.

Pontiac/Products – In addition, we may disclose your information to service providers and digital media providers who enable delivery of online advertisements to you.

INTEREST-BASED ADVERTISING

We believe that advertising is more effective and relevant when it is targeted to your interests and behaviors. Therefore, we may work with third parties who collect information on our Services through the use of cookies and similar methods in order to serve you with relevant advertisements on other services or to determine that you have seen advertisements we have served for our clients on other services. We also collect and process information to serve you with advertisements through other platforms and services that you use. You do have the ability to control certain advertising practices. We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA). You can learn more about interest-based advertising and opt-out of targeted advertising from certain providers with whom we work by visiting https://youradchoices.com/control and http://www.aboutads.info/choices. To learn how to opt-out of such targeted advertising through industry programs, see YOUR RIGHTS, CHOICES AND OPT OUT below.

LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We do not endorse any other websites and providers by providing such links, and our privacy policy applies only to your use of our Service. We are not responsible for the privacy policies of any websites and services we link to on our Service, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.

DATA RETENTION

We will retain your information for as long as your account is active or as needed for us to manage and provide our services and for our business needs. Even if we delete some or all of your personal information, we may continue to retain and use de-identified or aggregate data previously collected.

OUR CLIENTS

If you are a client or business partner of ours, then the contract between your company and PM shall prevail over this Privacy Policy.

YOUR RIGHTS, CHOICES AND OPT OUT

California Users – If you are a resident of California, you have certain rights under the California Consumer Privacy Act (“CCPA”) as described below.

1. Right to Know About Personal Information Collected, Disclosed or Sold

If you are a resident of California, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Deletion and Opt-out Rights), and subject to certain limitations that we describe below, we will disclose such information to you.

You have the right to request any or all of the following:

The categories of personal information we collected about you.
The categories of sources from which the personal information is collected.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.

2. Right to Request Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Deletion and Opt-out Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated.

Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to perform certain actions, such as detecting security incidents and protecting us from illegal activity, or an exception under the CCPA applies which allows us to retain the information.

3. Sale of Personal Information

We do “sell” your personal information, as that term is defined under the CCPA. This means that personal information, such as your IP address or data collected via a tracking cookie, may be provided to third parties for their own independent use.

4. Exercising Access, Deletion and Opt-out Rights

To exercise the access, deletion and opt-out rights described above, please submit a request to us by either:

Emailing us at privacy@progmechs.com or privacy@pontiac.media .
Filling out this form: https://go.pontiac.media/optout

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information. If you use an authorized agent to make request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. You have the right not to receive discriminatory treatment for exercising any of your privacy rights.

Industry behavioral advertising opt-out – You may opt-out of being tracked online by certain companies who are listed at http://www.aboutads.info/choices/ or http://www.networkadvertising.org/managing/opt_out.asp and may also learn more about online behavioral advertising at such websites. If you opt-out, you will still receive advertisements, but they will not be delivered to you by such companies from whom you have opted-out based upon your behavioral data possessed by the companies from whom you have opted-out. The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device, and you must repeat this process on each device or if your cookies are purged from your device. Cookie-based opt-outs are not effective on certain mobile services. Users may opt-out of certain advertisements on mobile applications or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, click on the following links:

iOS – https://support.apple.com/en-us/HT202074

Android – https://support.google.com/ads/answer/2662922?hl=en

You may also download and set your preferences on the DAA’s App Choices mobile application(s) available in Google Play or the Apple App stores. More information about opting out on mobile devices is available here – https://www.networkadvertising.org/mobile-choice/. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms automatically transmitted by web browsers for which we are cannot evaluate your choice

Nevada Users – If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at privacy@progmechs.com .

EEA & UK Users – If you are a situated in the European Economic Area, United Kingdom or Switzerland and the General Data Protection Regulation (“GDPR”) or a similar law applies, as a data subject, you have the following rights:

Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning them is being processed and provide access to such personal data. It also allows individuals to request details of the processing of their personal data including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
Right to rectify – This right allows individuals to rectify any inaccurate personal data about them.
Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

Programmatic Mechanics LLC is the Controller of all personal data we collect through the Service.

We shall only process your personal data pursuant to a lawful basis, which will usually be with your consent, when we have a legitimate interest, or to perform a contract to which we are subject. Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To exercise your rights under the GDPR or the UK GDPR, please contact us at privacy@progmechs.com . Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

If you are situated in the EU, UK or Switzerland and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.

SECURITY

We take the security of our data and information seriously. We take what we believe are reasonable precautions to protect against unauthorized access to our systems and to prevent data from being disclosed to unauthorized parties. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy at our discretion at any time. If we do make any changes, such change will appear on this page of our Service. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of the Service following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy.

CHILDREN UNDER THE AGE OF 16

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. 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 personal information from or about a child under 13, please contact us at privacy@progmechs.com .

UNITED STATES OF AMERICA / CROSS BORDER DATA TRANSFERS:

Our Service is maintained in the United States of America. By using the Service, you authorize the export of personal information to the USA and its storage and use as specified in this Privacy Policy. We transfer personal information from the EU, UK and Switzerland to the USA and other countries, some of which have not been determined by the European Commission or other regulators to have an adequate level of data protection. Information stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at privacy@progmechs.com .