Michael McMahon
Analytics driven marketer since 1990. Founder of three multi-million dollar agencies. Past clients have included Amazon, eBay, Macy's, The Wall Street Journal, Microsoft, Sprint, Match, AutoTrader, Wells Fargo and Bank of America.
(Last updated: December 4, 2018) –ROI Factory is committed to protecting the personal information of our customers and website visitors. It is important to us that you understand how we treat your personal information and we encourage you to read this Policy carefully.
This Privacy Policy (“Policy”) explains how we process information that we collect from users of our website at roifactory.com and the services available on our website (together, the “Site”), as well as from our former, current and prospective clients and other individuals that use our products and services or communicate with us. Please note, that this Policy only applies to us but not to any third-party websites that may process, share, or distribute your personal information or other information.
For the purposes of GDPR, ROI Factory is the controller of your personal information, unless you are explicitly told otherwise. Where processing of personal information is also undertaken by our affiliates, subsidiaries with whom you engage, they are joint controllers with ROI Factory for your personal information.
ROI Factory provides programmatic support, consulting and campaign management services, facilitates and manages access to third-party services, and provides an innovative platform to clients to bring it all together (our “Services“). We may receive, access or otherwise process personal information in order to provide our Services (the “Client Data”) to clients. ROI Factory will only process Client Data on behalf of and under the instructions of our clients, as set out in our client agreements, or where otherwise required by applicable laws. Our Clients are the data controllers of their respective Client Data, and we are the data processor.
We collect personal information directly from individuals, from third parties, and also automatically through the use of our Site. You do not have to provide us with your personal information to access much of our Site. However, if you choose not to disclose certain information, we may not be able to provide certain Services to you.
Information collected directly. We may collect personal information about you (such as your name, address, and contact details) directly from you. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, register for events we host or sponsor, register for an account, post comments on our Sites, or otherwise provide us information through the Sites. Generally, the information we collect includes your:
Automatically-collected information. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the Services or visit our Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the “Cookies and similar devices” section below.
We use the personal information you provide to respond to your request or inquiry and in the ordinary course of conducting our business, including as set out below:
We also create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.
Purpose of Processing /Legitimate Business Interests (see above) | Legal Bases of Processing (EU Users)* |
Providing Support and Services, Responding to Your Requests | Necessary to Enter into or Perform a Contract with You (upon your request, or as necessary to make the Services available)Our Legitimate Business Interests* |
Analytics and Improvement | Our Legitimate Business Interests**Establish, defend or protect our legal interests |
Personalization | Our Legitimate Business Interests** |
Marketing, Advertising | Our Legitimate Business Interests**With Your Consent |
Protect Our Rights and Prevent Misuse, Comply with Legal Obligation | Compliance with law Establish, defend or protect our legal interests |
General Business Operations | Our Legitimate Business Interests**Establish, defend or protect our legal interestsCompliance with law |
* For the personal data from the EU that we process, this column describes the relevant legal bases for such processing under GDPR (and local implementing laws of EU member states); this does not limit or modify the obligations, rights and requirements under the privacy laws of non-EU jurisdictions.
** For the personal data from the EU, the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Our legitimate interests include assessing and improving our products and services, understanding our clients’ needs and interests so that we can make our services more useful to clients, providing clients with news, information and marketing materials that are more relevant, providing training opportunities for employees, improving how we analyze and assess the success of client campaigns, developing trend and benchmark reports, and similar purposes.
We do not sell your personal information to third parties. In general, we disclose the personal information we collect as follows:
Like many websites, we use cookies to recognize you when you return to our website so that we can provide you with a customized experience. We may also use pixels, javascript, log files and other mechanisms to gather information about your use of our Site.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
Third-Party Analytics. We also use automated devices and applications, such as Google Analytics to evaluate use of our Services. We use these tools to gather non-personal data about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.
Do-Not-Track Signals. Our Site does not respond to do-not-track signals. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies) and set out in our Cookie Policy.
We work with third-party ad networks, analytics companies, measurement services and others (“third party ad companies”) to manage our advertising on third-party sites, mobile apps and online services. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.
See our Cookie Policy for information on the third parties that we work with, and how you can opt out of ads from them. For more information about third-party ad networks and to opt out of interest-based ads from many ad networks go to:
ROI Factory is headquartered in the United States, and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
If you are in the European Economic Area, and we process your personal information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of personal information when transferred to a third country. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EEA; you may request such details by contacting us as set forth in the “Contact us” section below.
Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information, please send your request to michael@roifactory.com. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
Individuals in the EEA have the following rights with respect to their personal data:
We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security.
As a general rule, we retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant personal information of clients and Site visitors for at least three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our clients instruct us on how long to retain Client Data, which we handle as a data processor. We may retain personal data for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.
The ROI Factory site is not intended for minors under the age of 16. We do not knowingly or specifically collect information about minors under the age of 16. If you believe we have unintentionally collected such information, please notify us so that we can delete this information from our servers.
From time to time, we may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. We will place a notice online when we make material changes to this the Policy. Additionally, if the changes will materially affect the way we use or disclose Information, we will notify you in advance of the change by sending a notice to the primary email address associated with your account or by posting a notice on our Site. We encourage you to periodically review this Policy for the latest information on our privacy practices.
If you have questions or concerns regarding the way in which your personal data is being processed or this Policy, please email us at michael@roifactory.com.
Analytics driven marketer since 1990. Founder of three multi-million dollar agencies. Past clients have included Amazon, eBay, Macy's, The Wall Street Journal, Microsoft, Sprint, Match, AutoTrader, Wells Fargo and Bank of America.