Privacy Policy

01Introduction and Scope

1.1 This Privacy Policy ("Policy") explains how [LEGAL ENTITY NAME], a [STATE OF FORMATION] limited liability company doing business as Imagine Being Seen ("Imagine Being Seen," "IBS," "we," "us," or "our"), collects, uses, discloses, retains, and protects Personal Data. It also explains the rights available to you and how to exercise them.

1.2 This Policy applies to Personal Data we process through: (a) the website located at https://imaginebeingseenads.com and https://imaginebeingseen.com, including all subdomains, pages, business profiles, directories, deal, event, and job listings (collectively, the "Site"); (b) QR codes, short links, and calls to action displayed on our mobile LED billboard trucks, digital billboard trailers, indoor display screens, event displays, and printed materials (collectively, the "Display Network"); (c) advertiser accounts, dashboards, and portals; and (d) email, telephone, text message, and in-person communications with us (together with the Site and Display Network, the "Services").

1.3 This Policy does not apply to: (a) the websites, apps, or privacy practices of businesses that advertise on or are listed through the Services ("Advertisers"); (b) third-party websites or services linked from the Services; or (c) information we process solely on behalf of an Advertiser under a written agreement, in which case that Advertiser's privacy notice governs.

1.4 By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, do not use the Services. Your use of the Services is also governed by our Terms of Service, which are incorporated herein by reference.

Key Definitions

1.5 For purposes of this Policy:

"Personal Data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. It does not include De-identified Data or Publicly Available Information.

"Sensitive Data" has the meaning given in the New Jersey Data Privacy Act, N.J.S.A. 56:8-166.4 et seq. ("NJDPA"), and includes data revealing racial or ethnic origin, religious beliefs, mental or physical health, sex life or sexual orientation, citizenship or immigration status, status as transgender or non-binary, genetic or biometric data, precise geolocation, certain financial information, and Personal Data of a known child.

"De-identified Data" means data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual, and that we maintain under reasonable technical and contractual safeguards against re-identification.

"Process" or "Processing" means any operation performed on Personal Data, including collection, use, storage, disclosure, analysis, deletion, or modification.

"Sale" means the exchange of Personal Data for monetary or other valuable consideration by us to a third party, as defined by applicable law.

"Targeted Advertising" means displaying advertisements to you based on Personal Data obtained from your activities over time across non-affiliated websites or online applications to predict your preferences or interests, as defined by applicable law.

"Consumer," "you," and "your" refer to any individual who uses the Services, including visitors, reviewers, job seekers, event attendees, and individuals acting on behalf of an Advertiser.

02Personal Data We Collect

2.1 We collect only the Personal Data that is adequate, relevant, and reasonably necessary for the purposes disclosed in this Policy. The categories below describe what we collect, the source, and examples.

2.2 Information you provide. You provide Personal Data when you submit the Advertise With Us form, the Contact form, a review, a request to manage or verify a review, a business claim or listing report, when you create or use an advertiser account, sign a contract, respond to a job posting through a link, or otherwise communicate with us.

2.3 Information collected automatically. When you use the Services, our servers and the technologies described in Section 5 automatically record certain device and usage data. We record QR scans, profile views, and contact clicks as event records so that we can report aggregate performance to Advertisers.

2.4 Information from third parties. We may receive Personal Data from: (a) Advertisers who provide their own staff or business contact details; (b) service providers such as our hosting, email, e-signature, and payment providers; (c) advertising and analytics partners, in aggregated or pseudonymous form; and (d) publicly available sources, such as business registration and public business listings, used to verify a business.

2.5 No precise geolocation. We do not intentionally collect precise geolocation from your device. Location information we hold is limited to the town you type, the display location tied to a QR code, and approximate location derived from your IP address.

2.6 No Sensitive Data requested. We do not request Sensitive Data. Please do not include Sensitive Data, financial account numbers, or government identification numbers in reviews, messages, or forms. If you voluntarily submit Sensitive Data, you consent to its Processing solely to respond to your submission, and we may delete it.

03How We Use Personal Data

3.1 We Process Personal Data for the following purposes:

1. To provide and operate the Services, including publishing Advertiser profiles, displaying deals, events, and job listings, enabling search, and connecting you with businesses whose ads you saw.

2. To respond to inquiries, including advertising inquiries, quote and proposal requests, and support requests.

3. To administer advertiser accounts and contracts, including onboarding, scheduling placements, producing creative, invoicing, collecting payment, and enforcing agreements.

4. To publish and moderate reviews, including verifying email addresses, detecting fraudulent, incentivized, or conflicted reviews, and preventing business owners from reviewing their own businesses.

5. To measure and report performance, including counting QR scans, profile views, and contact clicks, and providing Advertisers with aggregate or De-identified reports. We do not provide Advertisers with the identity of individual visitors.

6. To maintain safety, security, and integrity, including detecting spam, bots, abuse, and fraud, investigating listing reports, and protecting the rights and property of IBS, Advertisers, and users.

7. To improve the Services, including analyzing usage trends, fixing errors, and developing new features.

8. To market our own services, including sending advertising information to businesses that have requested it or have an existing business relationship with us, subject to your right to opt out.

9. To comply with law, including tax, accounting, record-keeping, and legal process obligations, and to establish, exercise, or defend legal claims.

10. For any other purpose disclosed to you at the time of collection or with your consent.

3.2 Secondary use. We will not Process Personal Data for purposes that are neither reasonably necessary to, nor compatible with, the purposes disclosed in this Policy unless we first obtain your consent.

3.3 Profiling and automated decisions. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, such as decisions about financial services, housing, insurance, education, criminal justice, employment, health care, or access to essential goods or services.

3.4 De-identified Data. We may create De-identified Data and aggregate statistics from Personal Data. We will maintain and use such data only in de-identified form, will not attempt to re-identify it except as permitted by law, and will contractually obligate any recipient to do the same.

04Cookies, Analytics, and Advertising Technologies

4.1 What we use. We and our service providers use cookies, local storage, pixels, tags, server logs, and similar technologies ("Cookies"). Cookies fall into these categories:

Strictly necessary: required for security, form submission, spam prevention, load balancing, and keeping advertisers signed in. These cannot be disabled through our Services.

Preferences: remember settings such as text size and filters you selected.

Analytics: help us understand how visitors use the Site and how QR codes perform. [LIST TOOLS, e.g., Google Analytics, WordPress/Jetpack statistics.]

Advertising: help us measure and deliver advertising for IBS's own services on third-party platforms. [LIST TOOLS, e.g., Meta Pixel, Google Ads tag. Delete this bullet if none are installed.]

4.2 Third-party content. Pages may load fonts, scripts, maps, or embedded content from third parties (for example, Google Fonts or map providers). When your browser requests that content, the third party receives your IP address and standard browser information, subject to that third party's privacy policy.

4.3 Targeted Advertising. We may use advertising technologies to show ads for IBS's services to people who have visited the Site on other platforms such as Meta (Facebook and Instagram) and Google. To the extent this constitutes Targeted Advertising under applicable law, you have the right to opt out as described in Section 4.4 and Section 8.

4.4 Your choices.

Universal opt-out signals. We treat a Global Privacy Control (GPC) signal or other legally recognized universal opt-out mechanism sent by your browser as a valid request to opt out of Targeted Advertising and any Sale of Personal Data for that browser or device. No further action is required from you.

Opt-out request. You may also opt out by emailing us at the address in Section 10 with the subject line "Opt Out."

Browser controls. Most browsers allow you to block or delete Cookies. Blocking strictly necessary Cookies may prevent parts of the Services from working.

Platform controls. You may adjust ad preferences directly with Meta, Google, and other platforms, and through industry tools such as the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org).

4.5 Do Not Track. Because there is no common industry standard for "Do Not Track" browser signals, we do not respond to them, except that we honor GPC as described above.

05How We Disclose Personal Data

5.1 We do not sell Personal Data. We do not sell Personal Data for money, and we do not share Personal Data with Advertisers for their own marketing purposes.

5.2 We disclose Personal Data only as follows:

1. Service providers (processors). Companies that host the Site, provide email delivery, e-signature (such as DocuSign), payment processing, customer relationship management, analytics, security, and IT support. They may Process Personal Data only on our instructions under written contracts requiring confidentiality, appropriate security, and deletion or return of data at the end of the engagement.

2. Advertisers, in limited form. We provide Advertisers with aggregate or De-identified performance data such as scan, view, and click totals. If you choose to contact an Advertiser by calling, emailing, visiting its website, or claiming a deal, you are dealing with that Advertiser directly and its own privacy practices apply.

3. The public. Reviews, review display names, star ratings, and Advertiser listing content are published on the Site and visible to anyone. See Section 6.

4. Advertising platforms. If enabled, the advertising technologies described in Section 4 may receive device and usage data, subject to your opt-out rights.

5. Legal, safety, and compliance. Law enforcement, courts, regulators, or other parties where we believe in good faith disclosure is required by law, subpoena, or legal process; necessary to protect the rights, property, or safety of IBS, our users, Advertisers, or the public; or needed to detect, prevent, or address fraud, security, or technical issues.

6. Professional advisers. Attorneys, accountants, auditors, and insurers, subject to duties of confidentiality.

7. Business transfers. In connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, Personal Data may be transferred to the successor or acquirer, which will be bound by this Policy or a policy at least as protective with respect to previously collected data.

8. With your consent or direction. For any other purpose disclosed at the time you provide the data or with your consent.

5.3 We may disclose De-identified Data and aggregate statistics without restriction, including in marketing materials describing the reach of the Display Network.

06Reviews, Public Profiles, and User Content

6.1 Reviews are public. When you submit a review, your display name, star rating, review text, and date are published and may be indexed by search engines, quoted by the reviewed business, and copied by others. Your email address is kept private and is used only to verify your review, prevent abuse, and let you manage your review.

6.2 Verification and moderation. We send a verification link to the email you provide. An administrator reviews submissions before publication. Email verification confirms that you control the email address; it does not confirm a purchase or customer relationship.

6.3 Your control. You may edit or request removal of your own review at any time using

"Manage my review" on the business profile or by contacting us. Removal from the Site does not remove copies made by third parties or cached by search engines.

6.4 Advertiser profiles. Information on Advertiser profiles, including names, addresses, phone numbers, hours, photos, and descriptions, is supplied by or for the Advertiser and is published because the business purchased advertising. Individuals named on a profile who object may contact us under Section 10.

6.5 Do not post Personal Data of others. Do not include another person's private contact details, Sensitive Data, or identifying information in a review or message. We may redact or remove such content.

07Data Retention and Security

7.1 Retention. We retain Personal Data only as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law. Our general retention periods are:

7.2 When retention periods end, we delete or de-identify Personal Data, or, if that is not feasible (for example, in backups), we isolate it from further Processing until deletion is possible.

7.3 Security. We maintain reasonable administrative, technical, and physical safeguards appropriate to the volume and nature of the Personal Data we hold. These include encrypted (HTTPS/TLS) transmission, hashed passwords, role-based access limited to personnel who need it, spam and bot protection, software updates, and vendor security review. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7.4 Your responsibility. Advertisers are responsible for keeping their login credentials confidential and for all activity under their accounts. Notify us immediately of any unauthorized use.

7.5 Breach notification. If we discover a breach of security affecting computerized Personal Information of New Jersey residents, we will notify the Division of State Police and affected individuals as required by the New Jersey Identity Theft Prevention Act, N.J.S.A. 56:8-161 et seq., and comply with any other applicable breach notification law.

08Your Privacy Rights

8.1 Rights available to you. Subject to applicable law, including the NJDPA, and regardless of whether we meet the law's applicability thresholds, we extend the following rights to all U.S. users:

8.2 How to submit a request. Email [PRIVACY EMAIL, e.g., privacy@imaginebeingseen.com or contracts@imaginebeingseen.com] with the subject line "Privacy Request," or call [PHONE NUMBER]. State which right you are exercising and provide the email address or account you used with us. Opt-out requests may also be made through GPC as described in Section 4.4.

8.3 Verification. To protect your Personal Data, we will verify requests (other than opt-out requests) by matching information you provide with information we hold, such as by sending a confirmation link to the email address on file. We will not require you to create an account. We may decline a request we cannot reasonably authenticate and will tell you why.

8.4 Authorized agents. You may designate an authorized agent to submit an opt-out request on your behalf. For other requests, we may require the agent to provide signed written permission and may ask you to verify your identity directly with us. A parent or legal guardian may exercise rights on behalf of a child.

8.5 Response time. We will respond within 45 days of receiving a request. We may extend this period once by an additional 45 days when reasonably necessary, and will inform you of the extension and the reason within the first 45 days. Information is provided free of charge once per 12-month period; we may charge a reasonable fee or decline requests that are manifestly unfounded, excessive, or repetitive.

8.6 Appeals. If we decline to act on your request, you may appeal by replying to our decision or emailing us with the subject line "Privacy Appeal" within 60 days. We will respond in writing within 45 days, explaining any action taken or not taken and the reasons. If your appeal is denied, you may contact the New Jersey Division of Consumer Affairs or the Office of the Attorney General at www.njconsumeraffairs.gov.

8.7 Exceptions. We may retain or decline to delete Personal Data where permitted by law, including to complete a transaction, comply with legal obligations, detect security incidents or fraud, defend legal claims, or carry out internal operations reasonably aligned with your expectations.

8.8 Residents of other states. If you reside in a state with its own consumer privacy law, you may have additional rights under that law. Contact us and we will honor them as required.

09Additional Disclosures

9.1 Children. The Services are directed to adults and businesses and are not intended for children under 13. We do not knowingly collect Personal Data from children under 13, consistent with the Children's Online Privacy Protection Act (COPPA). We do not knowingly Process Personal Data of individuals aged 13 to 17 for Targeted Advertising or Sale. Reviews and advertiser accounts are limited to users 18 or older. If you believe a child has provided us Personal Data, contact us and we will delete it.

9.2 Email marketing. Our commercial emails comply with the CAN-SPAM Act. Each marketing email includes an unsubscribe link, and we honor opt-outs within 10 business days. Transactional and account messages (such as review verification, invoices, and contract notices) are not marketing and may be sent even after you unsubscribe.

9.3 Calls and text messages. We will not send marketing text messages or make autodialed or prerecorded marketing calls to you without your prior express written consent as required by the Telephone Consumer Protection Act. Consent is not a condition of purchase. Reply STOP to any text to opt out; message and data rates may apply.

9.4 Third-party links. The Services link to Advertiser websites, maps, social media, and other third-party services. We are not responsible for their content or privacy practices. Review their privacy policies before providing them Personal Data.

9.5 Data location. We are based in New Jersey, and the Services are intended for users in the United States. Personal Data is stored and Processed in the United States. If you access the Services from outside the U.S., you do so at your own initiative and your data will be transferred to the U.S.

9.6 Changes to this Policy. We may update this Policy from time to time. We will post the updated Policy with a new "Last Updated" date. If we make material changes, including any new purpose of Processing Personal Data, we will provide notice on the Site or by email before the change takes effect and, where required by law, obtain your consent.

10Contact Us

Questions, requests, or complaints about this Policy or our privacy practices may be directed to:

[LEGAL ENTITY NAME] d/b/a Imagine Being Seen Attn: Privacy P.O. Box #6 Newton New Jersey 07860 Email: Privacy@imaginebeingsen.com