Introduction

Construction OC, ("Construction-OC.com", "us" or "we") offers a referral, advocacy, and analytics platform enabling brands (our "Clients")--whether those brands use websites or "apps," and across different types of devices--to allow their end users’ ("Users") to share, refer, and engage on those website and devices with content, and to derive additional insights into how their Users experience the brand. Extole recognizes and believes that data privacy is important to all Internet users, and therefore we design and operate our services in a privacy-first manner. This privacy policy describes how we collect, use, disclose, and secure data and describes your rights in determining what we do with the information that we collect or hold about you.
This Privacy Policy is divided into three parts, and is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions:
Collection and Use of Information from Our Services: This section explains how information is collected about our Clients' Users, and used, by Extole in connection with the provision of our products and services (the "Extole Services" or the "Services"). Collection and Use of Information from Our Website: This section explains how information is collected and used by us from our website visitors through our website located at www.extole.com (the "Website"), which includes the dashboard provided to our Clients located at my.extole.com. If you are a Client using our Extole dashboard, this section applies to the data we collect from you. Policies Applicable to Both Our Services & Our Website: This section lays out the parts of the Extole Privacy Policy that apply to both the Services and to the Website. Collection and Use of Information from Our Services What Information Does Extole Collect from Our Services? Below, we explain what information we collect on behalf of our Clients through the Services, and how we use it. We process information in a way that is relevant for the purpose for which it was collected as described below.
Services: Overview Extole provides a variety of Services intended to help Clients deliver content, including rewards and links, to their Users across a wide array of platforms, devices, and applications so that Users can share content, links, and rewards with one another. Extole helps Clients by providing analytics to Clients. This information is used by the Client to better inform marketing and product decisions as well as to provide improved user experiences.
Extole has no direct relationship with Users. Extole's Services are provided when Extole Clients install on their platforms “Extole Mechanisms” (including links, pixels, direct platform integrations, etc.) that capture the User action on behalf of the Client. By associating the information collected from these Mechanisms, Extole creates and stores identifiers unique to individual clients in the Extole platform, and then uses a variety of techniques to connect these User actions and identifiers together. Some of these common connection techniques include a direct pass-through of identifiers from platform to platform. These techniques help Clients match Users and issue rewards based on those matches. Extole stores this information separately for each Client program and does combine specific actions and information about individuals between different Client programs.
The key use cases of Extole's service are:
To support Clients in implementing refer-a-friend programs typically using rewards based on key events such as purchase. For example, Extole helps a Client create and deliver a sharing UI on a Clients website or app so that Users can create links and send them to other Users in email, over social networks, and directly to recommend purchase or sign-up. Extole tracks the events in this referral process and helps Clients deliver reward to Users. To report individualized and aggregated analytics metrics about the performance of the Client's referral and advocacy initiatives to the Client directly. For example, Extole can tell a Client how many Users shared, visited their website, registered for their service, and/or purchased. Extole can also tell a Client about the rewards issued as a result of those events. To assist the Client by presenting real time, targeted offers and content to their Users depending on Client determined criteria in order to deliver more relevant referral and advocacy content and rewards. For example, a Client can use Extole Mechanisms to provide a tailored reward like a coupon code in the Client's website to users who have interacted with the Client's app and/or website in the past. Extole requires that each Client commit to share with Extole only information that it has lawfully obtained (including, where necessary, by obtaining consent from Users, or from their parents for children under