Last Revised: June 1, 2020.
Personal Information Acquired About You
Depending on the circumstances and which Service you use, we may collect, obtain or otherwise acquire the following types of Personal Information about you, and we make and retain inferences drawn from such information: 1. Identifiers, such as your name, signature, postal address, zip code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID. 2. Certain characteristics, such as gender, marital status, nationality, and country of origin, that are protected by applicable law. 3. Commercial information, such as purchase history. 4. Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails. 5. Geolocation data, such as the precise physical location of your Device. 6. Audio, electronic, visual, thermal, olfactory, or similar information, such as voice recordings, video recordings, physical characteristics or description, and photos. 7. Professional or employment-related information, such as occupation, employment history and record, and resume. 8. Education information such as academic record. 9. While we generally do not obtain other Personal Information that is often considered “highly sensitive,” such as biometric information (e.g., fingerprints, facial recognition images), financial account information (e.g., bank account, credit, debit or other payment card numbers or other financial information), government issued identification numbers (e.g., social security number, drivers’ license number, passport number, or state identification card number), insurance policy number, or medical, health or insurance related information, we may do so when such Personal Information is necessary to offer you certain services.
3. How We Acquire Personal Information
- Personal Information You Provide. We often receive Personal Information because you provide it to us. For instance, when you enter a contest, complete a survey, purchase a Product, or register and/or set up an account/profile or attend a conference or event, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Personal Information such as your age, gender, and preferences may also be requested. In addition, we may acquire your Personal Information when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire Personal Information that you provide about other people, for example, when you use our “refer-a-friend” email feature or purchase one of our Products as a gift.
- Personal Information Automatically Collected. The Service also automatically collects certain information, some of which may be deemed Personal Information. The information collected may include, without limitation, information about your Device, such as the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect such information even if the Service is not open on your Device or you’re not logged in.
- Personal Information Acquired Elsewhere. We may also acquire your Personal Information offline, from third parties, or otherwise outside of the Service. For example, we may purchase or otherwise acquire Personal Information from third party consumer data suppliers/resellers, data enrichment providers and aggregators, business contact databases, government entities, and our affiliates.
- Social Network Integration. If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Service, we may receive Personal Information that has been made available to those services, including Personal Information about your contacts on those services. For example, some social networking services allow you to push Content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. You should make sure you are comfortable with your Personal Information the third party social networking services may make available to us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We treat Personal Information that we receive through third-party social networking services in the same ways as all of your Personal Information we receive through our Service.
- Be Careful Publicly Posting Personal Information. Please be aware that Content and Personal Information that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all Personal Information, especially sensitive Personal Information, that you may wish to post.
4. How We Use Your Personal Information
- Processing Your Requests. We use your Personal Information to process your request for Content, to process your attendance at an event or conference, and/or to process your request for Product(s). For example, if you subscribe to any of our Products we may use your e-mail address to send you a confirmation notice and your mailing address to send you the Product. Similarly, if you enter a contest, we will use your Personal Information to notify you if you are a winner. If you enter a contest or submit Content to us (e.g., a “letter to our editors” or online review or comment), we may also publish your name, screen name, home town and other Personal Information you have provided to us.
- Administering the Service. We also use and share your Personal Information for any lawful purpose in connection with administering the Service, including without limitation for customer service, to help diagnose problems with servers, to improve Products that we offer by tailoring them to perceived preferences, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users’ movements around the Service and elsewhere on the web or across apps and/ devices. Your geolocation data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location.
- Access by Third Parties. 1. Service Providers. We allow access to your Personal Information by Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services. For example, Service Providers help us with technical maintenance, market research, community and forums management, auctions, e-commerce, personal/job search, list rental, data coop management, and other advertising functionality, including OBA, as well as credit/debit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. While we may seek to require Service Providers to follow appropriate privacy policies and will not authorize them to use your Personal Information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
- Third Party Businesses. There are also times when you provide Personal Information to us in areas of the Service that may be managed or participated in by one or more Third Party Business(es). Moreover, we rent, sell, share, and transfer Personal Information to (i) list buyers who market their goods and services (commonly known as “list rental”); (ii) our advertising, marketing and sponsorship clients to market their goods and services; (iii) “data coops”, which are pooled databases containing the customer information of multiple publishers to enable the marketing use of such customer information by participating publishers; and (iv) consumer data suppliers/resellers, data enrichment providers and aggregators, and other entities in the online behavioral advertising ecosystem for purposes of OBA, data optimization, lead generation, and other data driven projects. In all such cases, the Personal Information may be used by us and by such Third Party Business(es) for their own purposes, each pursuant to its own policies. While we may seek to require Third Party Businesses to follow appropriate privacy policies, we do not bear any responsibility for any actions or policies of third parties.
- Related Entities. We share your Personal Information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section IV.
- Categories of Third Parties. For the sake of clarity, here is a list of recipients to whom we disclose Personal Information:
- Service Providers;
- Third Party Businesses;
- Related Entities;
- Governmental and law enforcement officials, or parties to legal proceedings.
- Persons involved in an acquisition of our business or assets.
- Marketing Communications. We may also use your Personal Information to communicate with you about new features, events or Products offered by us and Third Party Businesses, including our advertising, marketing and sponsorship clients.
- Employment Opportunities. If you provide your Personal Information to us in connection with an employment inquiry, we will use your Personal Information to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your Personal Information on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.
- Transfer or Sale of Our Business. As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Personal Information may be among the transferred assets.
- Combining Information. We may merge, co-mingle, or otherwise combine information, including Personal Information, in furtherance of the purposes above.
6. Cookies and Related Technologies; Do Not Track (DNT)
- Cookies/Local Device Storage. The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Businesses may independently use Local Device Storage in connection with the Service in a way that collects Personal Information for the purposes described in the respective privacy policies, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control and tailor the display of ads to you based on your preferences, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage.
- You May Disable Local Device Storage. If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.
- Tracking Technologies. In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”) on the Service, including in our communications with you, such as within e-mail and text messages and push notifications. We and Third Party Businesses use Tracking Technologies to determine which messages have been opened by recipients, and for all or some of the same lawful purposes described above for use of Local Device Storage.
- Do Not Track (DNT). Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitor’s browser. As discussed below, you may opt out of the use of your Personal Information for online behavioral advertising by third parties at any time.
8. Transfer of Your Personal Information Among Jurisdictions
Notice to California Customers – Your Privacy Rights
Consumer Privacy. The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information.
Know the ways in which we acquire, use, share, disclose and otherwise process your Personal Information; • Know the specific pieces of your Personal Information that we hold; • Request the deletion of your Personal Information, subject to several exceptions; and • Not to be denied goods or services for exercising these rights
California residents also have the right to opt-out of the “sale” of their Personal Information. We put “sale” in quotation marks because the CCPA considers some transfers of Personal Information to third parties in exchange for value as “sales,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with Third Party Businesses to further their own commercial purposes such as generating profiles about individuals. California residents can exercise this right. If we have actual knowledge that a California resident is younger than 16, we will request opt-in consent before selling their Personal Information. Note that we can still share Personal Information with third parties if those transfers aren’t “sales,” such as with our Service Providers.
Depending on the circumstances and which Service you use, we have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
- Protected characteristics
- Commercial information
- Geolocation data
- Internet or other electronic network activity information
- Financial, medical, or health insurance information
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional information
- Education information
- Inferences drawn from any of the above information categories.
Depending on the circumstances and which Service you use, we have “sold” (as defined in the CCPA) the following categories of your Personal Information in the preceding twelve (12) months:
- Protected characteristics
- Commercial information
- Geolocation data
- Internet or other electronic network activity information
- Inferences drawn from any of the above information categories, along with the following categories: (i) financial, medical, or health insurance information; (ii) audio, electronic, visual, thermal, olfactory, or similar information; (iii) professional information, and (iv) education information.
- Shine the Light. California’s “Shine the Light” law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing.