Privacy Policy

Introduction

 

At Spectro Agency, we respect the privacy of our clients and their customers, and we are committed to complying with all applicable laws and regulations related to data privacy and protection. This data policy outlines the requirements and restrictions that we must adhere to when accessing and using Marketing Data or Marketing API from LinkedIn.

 

a. Analytics Data

We may only use, distribute, or make available Analytics Data to provide reporting and billing to Authorized Clients. Such reporting shall relate to the performance, effectiveness, and optimization of the relevant LinkedIn advertising, Page, or Member Profile accounts. "Analytics Data" means Ad Analytics Data, Page Analytics Data, or Member Analytics Data (along with our analysis, insights, and derivatives thereof, including Aggregated Marketing Data as defined below).

We may aggregate Analytics Data from LinkedIn advertising, Page, or Member Profile accounts controlled by different Account Managers ("Aggregated Marketing Data"); provided that:

 

(i) We maintain the specific, segregated data regarding each Account Manager's LinkedIn Accounts as confidential and do not disclose it to any third party (other than Authorized Clients);

 

(ii) Such Aggregated Marketing Data does not include any Member Data (as defined below);

 

(iii) Such Aggregated Marketing Data would not allow any third party to identify or infer any Account Manager or any user of any LinkedIn Service (or data specific to any Account Manager or user of any LinkedIn Service);

 

(iv) We use and disclose such Aggregated Marketing Data only for the purpose of providing reporting to our Clients relating to optimization of marketer results from LinkedIn advertising, Page, or Member Profile accounts; and

 

(v) Any such use or disclosure is agreed to by the Account Manager that controls the relevant LinkedIn Accounts.

If Analytics Data includes any of the data types described in Sections 3.1(d) ("Organization Profile Data and Standardized Data") or 3.1(e) ("Member Data"), any such data is subject to the restrictions included in those sections, notwithstanding anything to the contrary in this Section 

 

3.1

 

b. Data Transferred to LinkedIn

We represent and warrant that we have all necessary rights and a legal basis under all applicable privacy and data protection laws and regulations for the transfer of any data to LinkedIn (including Audiences Data and Conversions Data) in connection with our Marketing API Integration.

 

c. Lead Form Response Data

We may only use and disclose Lead Form Response Data on behalf of the Authorized Client. We must not:

 

(i) create a database of Lead Form Response Data collected from multiple unaffiliated LinkedIn Accounts;

 

(ii) commingle Lead Form Response Data with any other data for the purpose of supplementing, verifying, or appending to user profiles (or portions thereof), other than to the extent permitted by the Ads Agreement.

If Lead Form Response Data includes any Member Data, any such Member Data is subject to the restrictions included in Section 3.1(e) ("Member Data"), notwithstanding anything to the contrary in this Section 3.1(c).

 

d. Organization Profile Data and Standardized Data

If we receive access to any organization profile data from a Page ("Organization Profile Data"), including logo, location, industry, or size of the subject organization, or any LinkedIn standardized data ("Standardized Data"), including standardized locations, industries, degrees, job functions, and other fields as specified in the Developer Documentation, we may only use and display such data via our Marketing Application to support the relevant Marketing Services for which the data was made available to us.

We must not:

 

(i) export, transfer, or distribute any Organization Profile Data or Standardized Data to any third party (other than as necessary to transfer reporting data from LinkedIn Accounts to Authorized Clients);

 

(ii) create any derivative of Organization Profile Data or Standardized Data (e.g. by modifying such data or by combining it with other data sources.

 

f. Compliance with Laws and LinkedIn Policies. You must comply with all applicable laws and regulations, including but not limited to privacy and data protection laws and regulations, in connection with your access to and use of Marketing Data and the Marketing API. You must also comply with LinkedIn's policies and guidelines, including but not limited to the LinkedIn Developer Policies, the LinkedIn Marketing Developer Platform Terms of Use, and the LinkedIn Ads Agreement. You are responsible for ensuring that your use of Marketing Data and the Marketing API does not violate any third-party rights or LinkedIn's policies and guidelines.

 

g. Data Security. You must maintain appropriate technical and organizational measures to protect Marketing Data from unauthorized access, use, or disclosure. You must also comply with all data security requirements set forth in LinkedIn's policies and guidelines, including but not limited to the LinkedIn Developer Policies and the LinkedIn Marketing Developer Platform Terms of Use.

 

h. Data Retention and Deletion. You must retain Marketing Data only for as long as necessary to provide the relevant Marketing Services to the Authorized Client or as required by applicable law. You must promptly delete or return all Marketing Data upon request by LinkedIn or the relevant Account Manager, or upon termination or expiration of your agreement with the Authorized Client.

 

i. Data Breach Notification. In the event of a data breach involving Marketing Data, you must notify LinkedIn and the relevant Account Manager promptly and in accordance with applicable law. You must also take all necessary measures to mitigate the effects of the data breach and prevent future breaches.

 

j. Audit Rights. LinkedIn may audit your compliance with these data requirements and restrictions at any time, upon reasonable notice and during normal business hours. You must cooperate fully with any such audit and provide LinkedIn with access to all relevant records, systems, and personnel.

 

k. Indemnification. You agree to indemnify, defend, and hold harmless LinkedIn and its affiliates, officers, directors, employees, and agents from and against any and all claims, damages, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to your access to or use of Marketing Data or the Marketing API, your breach of these data requirements and restrictions, or your violation of any applicable law or LinkedIn policy.

 

l. Miscellaneous. These data requirements and restrictions are subject to change by LinkedIn at any time, and your continued access to or use of Marketing Data or the Marketing API constitutes your acceptance of any such changes. These data requirements and restrictions constitute the entire agreement between you and LinkedIn with respect to your access to and use of Marketing Data and the Marketing API, and supersede all prior or contemporaneous agreements or understandings, whether written or oral, relating to the same subject matter. These data requirements and restrictions shall be governed by and construed in accordance with the laws of the State of California, without giving effect to any principles of conflicts of law. Any dispute arising out of or related to these data requirements and restrictions shall be resolved exclusively in the state or federal courts located in Santa Clara County, California, and you hereby consent to the jurisdiction of such courts.