Privacy Policy
Effective Date: May 1st 2020
ProMedia
("Company" "we" or "our") is committed to
advising you of the right to your privacy and strives to provide a safe and
secure user experience. This Privacy Policy explains how we collect, store
and use personal information provided by you on our Website. By accessing
and using our Website, you explicitly accept, without limitation or
qualification, the collection, use and transfer of the personal information
provided by you in the manner described in this Privacy Policy. Please
read this Policy carefully, as it affects your rights and our liabilities under
the law. If you disagree with the way we collect and process personal
information, please do not use our Website.
1.
Information We Collect.
1.1.
We collect general types of information about you when you visit and use our
Website; examples include personal information, demographic information,
behavioral information, and indirect information. Sometimes we collect
combinations of these types of information:
1.1.1. No Personal Information is Collected. We
do not collect information that can be used to identify you or any other Individual
to whom the information may relate such as your name, address, telephone
number(s), mobile numbers and email address, credit card number(s), bank
account(s), employment status or self-employment or other unique information
about you.
1.1.2.
Demographic Information. Is information that may or may not be
unique to you in the sense that it refers to selected population
characteristics. Such information may include, but is not limited to, zip
code, mobile phone carrier, age, gender, salary range, education, marital
status, occupation, military service, industry of employment, personal and
online interests. When we can identify you
personally through the use of this information, it becomes
Personal Information.
1.1.3.
Behavioral Information. Is information which is automatically
collected when you use our Website. This information includes the areas
of our Website that you visit, what services you access or ordered, information
about your computer hardware and software, including your IP address,
geographic location, browser preference, operating system type, domain names,
times that you access the internet, and other websites you have visited.
When we can identify you personally through the use of this
information, it becomes Personal Information.
1.1.4.
Third-Party Information. Is information about you that is acquired
from a third-party which may include personal, demographic, behavioral and
indirect information. This collection may also include, but not limited
to, first party cookies, third-party cookies, anonymous cookies, persistent
identifiers, email opt-in records and search engine keywords. We have no
access or control over these cookies and other tracking devices used by third
parties including advertisers and networks, internet service providers, data
analytics providers or social networks and platforms. We have no
responsibility or liability for the policies and practices of these
parties. When we can identify you personally through the use
of this information, it becomes Personal Information.
1.1.5.
Web Technology Information. Is information automatically collected
from you when you visit our Website. This includes internet protocol
("IP") addresses, browser type, internet service provider
("ISP"), referring/exit pages, operating system, date/time stamp,
and/or clickstream data. This information is collected from the use of
cookies, Web beacons or JavaScript.
1.1.6.
No Information Collected from Children. We will never knowingly
collect any Personal Information from children under the age of 16. If we
obtain actual knowledge that we have collected Personal Information about a
child under the age of 16, that information will be immediately deleted from our
database. Because we do not collect such information, we have no such
information to use or to disclose to third parties.
1.1.7.
No Sensitive Health Information is Collected. We do not collect
information about past, present or potential future medical conditions or
treatments. Nor do we collect any biometric information.
2.
Collection of Information Through Cookies, Web Beacons, and JavaScript.
2.1.
Generally, we as well as third-party vendors, networks, ISP(s) and supporting
advertisers use technologies such as cookies, web beacons, and java
scripts. These technologies collect internet protocol ("IP")
addresses, browser type, internet service provider ("ISP"),
referring/exit pages, operating system, date/time stamp, and/or clickstream
data. This information is used to analyze trends, administer our Website,
track users' movements through our Website and gather demographic information
about our user base as a whole. We may receive reports based on
these technologies on an individual or aggregated basis. California residents
have the right to know if we respond to do not track signals or cookies.
We do not respond to such signals or cookies.
2.1.1.
Cookies. "Cookies" are a feature in your browser
software. If enabled, cookies store small amounts of data on your
computer about actions you take on the pages of our Website. Cookies
assist us in tracking which of our features you visit most often, and what
content you viewed on past visits. When you visit this website again,
cookies allow us to remember your settings and may be used for
authentication. We may use cookies to keep track of the number of return
visits, accumulate and aggregate statistical information generally pertaining
to our Website, and deliver specific content to you based on your past viewing
history. You can disable cookies, although our Website may not function
properly for you. Your browser preferences can be modified to accept or
reject all cookies or request a notification when a cookie is set. You
may read more about cookies at http://cookiecentral.com/faq/ }
2.1.2.
Third-Party Cookies. We allow third-party vendors and advertisers
to set their own cookies on and through our Website. We have no control
over the practices of those third parties and are not responsible for their
technology or tracking. We encourage you to review the policies of such
persons or entities on their websites. We use various ad services
provided by Google that connects the activity on our Website with their
advertising network and they may use cookies that collects information
regarding certain patterns in your browsing history. To opt-out of this
tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google's Analytics
Advertising. This includes: (i) Remarketing with
Google Analytics; (ii) Google Display Network Impression Reporting; (iii)
Google controlled Campaign Manager integration; and (iv) Google Analytics
Demographics and Interest Reporting. Google uses cookies to track
activity performed by Google Analytics and its AdWords or DoubleClick
cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis
service. Google utilizes the data collected through its cookies to track
and examine the use of this site, to prepare reports on its activities, and to
share them with other Google services. You may opt-out of the Google
Analytics service using Google's Browser Add-on here https://tools.google.com/dlpage/gaoptout/.
2.1.3.
Social Media Cookies. Our Website includes third-party social
media features. These features may collect your IP address, which page
you are visiting on our Website, and may set a cookie to enable the feature to
function properly. Social media features are either hosted by a
third-party or hosted directly on our Website. Your interactions with
these features are governed by the Privacy Policy of the company providing it.
2.2.
Web Beacons. We use electronic images known as Web Beacons
(sometimes called single-pixel gifs, clear gifs or action tags) which allow us
to collect information about your visit to our Website, measure and improve the
effectiveness of advertisements and track delivery of advertising. Web
Beacons collect only a limited set of information including a cookie number,
time and date of page view, as well as a description of the page on which the
Web Beacon resides. We may also use Web beacons in email messages sent to
you. This allows us to determine if you opened or acted upon the email
message. Because Web beacons are the same as any other content request,
you cannot opt-out or refuse them. However, they can be rendered
ineffective by either opting-out of cookies or changing the cookie setup in
your browser.
2.3.
JavaScript. We may also use JavaScript. JavaScript is a computer
language that enhances the functionality of websites, particularly with respect
to pictures. We use it to analyze and improve our Website's
functions. You may deactivate JavaScript through your browser settings or
activate it the same way. If you disable JavaScript, you will not be able
to use some of the functions of our Website.
3.
How We Use Information Collected.
3.1.
Providing Services and Products. We use the information we gather
on our Website to provide you with the services and or products you have
requested. This may include passing your information on to a third-party
to provide such services or products. We do not control the privacy
practices of third parties. If you have any questions or wish to remove
your information from the third-party databases, you will need to contact that
party directly.
3.2.
Improving Our Website. We use the information we gather to respond
to any inquiries you make, operate and improve the functionality of our
Website, and deliver the products and services advertised on our Website.
We use the same for testing, research, analysis and product or marketing
development. Our services include the display of personalized products,
content, and advertising, relating to your experience and interests. This
includes maintaining and improving the safety, security and integrity of our
Website, databases and technology assets.
3.3.
Promotions and Communications with You. We also use the
information we gather to promote our and third-party services and products to
you that might be of interest to you. We also use the information we have
gathered to respond to your inquiries, concerns or requests. If your
request is made through a third-party, we may use the information to respond to
their requests.
4.
Disclosure of Information to Others.
4.1.
We will share your Personal Information with third parties and service
providers as described in this Privacy Policy.
4.1.1.
Product and Service Delivery. We share all categories of
information set out in this policy with third parties who help us in the
delivery of the products and services you have requested.
4.1.2.
Website Functionality. We share all categories of information set
out in this policy with third parties we employ to perform technical functions
on our behalf. Examples include third parties who host our Website,
analyze our data, provide marketing assistance, process credit card payments,
and provide customer service as set forth above.
4.1.3.
Third-Party Products and Services. We share all categories of
information set out in this policy with third parties including affiliated
entities, service providers, and data aggregators with your information with
third parties who will provide you with their opportunities, products or
services. Again, this includes your personal and non-personal
information, and includes your interests and preferences, so they may determine
whether you might be interested in their products or services.
4.1.4.
Anonymized information. We share aggregated anonymous information
about you, combined with other persons using our Website with third parties, so
that they can understand the kinds of visitors that come to our Website, and
how those visitors use our Website and promotion of our marketing. This
includes demographic information and behavioral information.
4.1.5.
Legal Process. We disclose your information if legally required to
do so, or at our discretion, pursuant to a request from a governmental entity,
or if we believe in good faith that such action is necessary to: (a) conform to
legal requirements or comply with legal process; (b) protect our rights or
property, or our affiliated companies; (c) prevent a crime or protect national
security; or (d) protect the personal safety of users or the public.
4.1.6.
Acquisition or Merger. We may disclose and transfer your
information to a third-party who acquires any or all of our business,
whether such acquisition is by way of merger, consolidation or purchase of all
or a substantial portion of our assets. In the event we become the
subject of an insolvency proceeding, whether voluntary or involuntary, we or
our liquidator, administrator, receiver or administrative receiver may sell,
license or otherwise dispose of, such information in a transaction approved by
the court.
5.
Third-Party Collection and Use of Information.
5.1.
Third parties collect and use information about you on or through our Website
in the following way:
5.1.1.
Analytics. As described above, we use third parties to monitor,
analyze and report on the traffic to, from and within our Website and email
messages.
6.
Security.
6.1.
We endeavor to safeguard and protect your information. When you submit
information on our Website, such information is protected both online and
offline. We have security measures in place to protect against the loss,
misuse, and alteration of personal information under our control. The
servers in which we store your information are kept in a secure physical
environment. The servers have industry standard firewalls. Access
to such servers is password protected and access by our employees is
limited. Currently, we use Secure Socket Layer software ("SSL")
to protect data and to secure any transactions. SSL encrypts information
including credit card number(s), and names and addresses, as they are
transmitted over the Internet. Please be advised that, although we take
commercially reasonable technological precautions to protect your data, no data
transmission over the Internet can be guaranteed to be 100% secure; therefore,
we cannot and do not warrant that your information will be absolutely
secure. Any transmission of data at or through our Website is at your own
risk. However, access to your information is strictly limited and not
accessible to the public.
7.
Changes to Privacy Policy.
7.1.
We reserve the right to make material changes to the substance of this Privacy
Policy. We will post those changes through a prominent notice on the
website, so that you will always know what information we gather, how we might
use that information, and to whom we will disclose it.
8.
California Residents Rights.
8.1.
Right to Know About Personal Information Collected, Disclosed, or Sold.
8.1.1. You
have the right to request that we advise you what Personal Information we
collect, use, disclose, and sell that belongs to you. Personal
Information does not include: (a) Publicly available information from
government records; (b) De-identified or aggregated consumer information; (c)
Information excluded from the CCPA's scope, like health or medical information
covered by the Health Insurance Portability and Accountability Act of 1996
("HIPAA"); (d) Personal Information covered by certain
sector-specific privacy laws, including the Fair Credit Reporting Act
("FRCA"), the Gramm-Leach-Bliley Act ("GLBA"), California
Financial Information Privacy Act ("FIPA"), or the Driver's Privacy
Protection Act of 1994 ("DPPA").
8.1.2. You
may submit a verifiable consumer request to obtain the specific Personal
Information we have collected about you either through our California Resident
Portal form or you may email us at privacy-team@promedia.com.
8.1.3. Upon
receiving your information, we are required to verify that you are the same
consumer with whom we have the information in our systems. To
verify your identify, we will require that you fill out the portal
form in its entirety which includes your name, address, email address and may
include other Personal Information used to identify you.
8.1.4. As
set forth in our primary Privacy Policy, we collect several types of information
about you when you visit and use our Website; examples include Personal
Information, demographic information, behavioral information, and indirect
information. Sometimes we collect combinations of these types of
information.
8.1.5. Personal
Information has been collected from the following categories of sources:
a.
Information collected directly and indirectly from your activity on our website
and your interactions or communications with us. This includes your
Personal Information provided by you in connection with obtaining a certain
product or service offered by us or one our network providers or advertisers.
b. Information
you provide us on this website.
c. Information
we received directly or indirectly from our clients or their agents in the course
of providing services to you and others.
e. Analytics
companies who provide demographic information such as gender, zip code, or any
information that is not tied to your Personal Information. In addition,
we may receive information about you from other online or offline sources,
including third parties from whom we validate consumer self-reported
information, and verify information we already have about you. This helps
us to update, expand and analyze our records and provide products and services
that may be of interest to you.
f.
We also collect information provided by Service Providers and other third
parties as set out in our main Privacy Policy, our advertisers, ad networks and
third-party technology companies.
8.1.6. We
have disclosed, shared and/or received compensation for our disclosure of
Personal Information for the following commercial/business purposes in the
preceding 12 months:
a. To obtain the services or products you have registered for on our
Website.
b. To allow a third-party to market their products or services to
you.
c. To provide you with information, products or services that you
request from us or resolve consumer concerns or request to opt-out of
marketing.
e. To improve our website, products and services, and present its
contents to you including testing, research, analysis and product development.
f. To maintain the safety, security, and integrity of our Website,
platforms as well as products and services, databases and other technology
assets, and business.
g. As described to you when collecting your Personal Information or
as otherwise set forth in the CCPA.
8.1.7. We
have disclosed Personal Information to our Service Providers and the following
categories of third parties:
a. Our affiliated entities.
b. Third parties to whom you or your agents authorize us to disclose
your Personal Information in connection with products or services we and/or
third parties provide to you.
8.1.8. We
do not collect, distribute, share or sell the Personal Information of anyone
under the age of 16.
8.2. Right
to Request Deletion of Personal Information.
8.2.1. You
have a right to request the deletion of your Personal Information if we have
collected or maintained it in the past 12 months.
8.2.2. You
may submit a verifiable consumer request to delete your information using our
and fully fill out the request form or contact us by email at privacy-team@promedia.com or by telephone 800-506-2732.
8.2.3. Once
we receive and confirm your verifiable consumer request, we will disclose to
you the following:
a.
The categories of Personal Information we collected about you.
b. The
categories of sources for the Personal Information we collected about you.
8.2.4. This
policy has disclosed our business or commercial purpose for collecting or
selling that Personal Information and the categories of third parties with whom
we shared that Personal Information.
8.3.
Right to Opt-Out of the Sale of Personal Information. You have the
right to opt-out of any sale of your Personal Information by us. If you
are requesting a product or service, this is an exemption from this right, and
we will process your request. However, you have the right to cease all
further sale of your Personal Information.
8.4.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights.
You have a right not to receive discriminatory treatment by us for the exercise
of these privacy rights conferred by the CCPA.As such, we will not deny you
goods or services, charge you different prices or rates for goods or services,
or deny you discounts or other benefits; nor will we provide you a different
level or quality of goods or services or recommend a different level or quality
of goods or services.
8.5.
Authorized Agent. Only you or a person registered with the
California Secretary of State that you authorize to act on your behalf, may
make a verifiable consumer request related to your Personal Information.
8.6.
Contact Us. Contact us for more information or with any questions
either through our or by email at privacy-team@promedia.com or by telephone
800-506-2732.
8.7. Limitations
on Requests. You may only make a verifiable consumer request for
access twice within a twelve (12) month period. The verifiable consumer
request must: (a) Provide sufficient information that allows us to reasonably
verify you are the person about whom we collected Personal Information or your
authorized agent; (b) Describe your request with sufficient detail that allows
us to properly understand, evaluate, and respond to you; (c) We cannot respond
to your request or provide you with Personal Information if we cannot verify
your identity or authority to make the request and confirm the Personal
Information relates to you; (d) Making a verifiable consumer request does not
require you to create an account with us. We will only use Personal
Information provided in a verifiable consumer request to verify the requestor's
identity or authority to make the request.
8.8. Response
Time and Response Format. We make every effort to respond to a
verifiable consumer request within forty-five (45) days of its receipt.
If we require more time (up to 90 days), we will inform you of the reason and
extension period in writing. We will deliver our written response by mail
or electronically, at your option. Any disclosures we provide will only cover
the twelve (12) month period preceding the verifiable consumer request's
receipt. The response we provide will also explain the reasons why we
cannot comply with a request, if applicable. We will provide our response
in a manner that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance to you.
8.9. Changes
to California Resident Privacy Notice. We reserve the right to amend
this privacy notice at our discretion and at any time. When we make
changes to this privacy notice, we will enforce the terms of the new policy
going forward. You will receive no other notice than an updated posting
on this page. Please check back each time you use or visit our
Website.
9. Contact
Information.
9.1.
If you have any questions or comments about this Privacy Statement, please do
not hesitate to contact us at:
Email: privacy-team@promedia.com
Telephone
Number: 1-800-506-2732