WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Information You Voluntarily Submit to the Sites: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Services or use certain Services. Personal Data may include, but is not limited to, the below:
- Your name and email address
- Your website URL and name
- Company name
- Phone number
- Billing information
- Work history
Mediavine partners with the following data processors to provide the Services:
Please see each partner’s privacy policies, as provided herein, for more information.
Automatically-Collected Information: We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect usage data, which are information about actions you take when using the Website, such as links clicked. When you use Grow, we may collect your IP address. Mediavine Publishers that utilize the Video Player may collect your IP address.
What are cookies? A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Sites and Service. The Cookie will collect information relating to your use of our Sites, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Sites and Service via a link from third party site, the URL of the linking page. In addition to Cookies, our Sites may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Sites and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Sites, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Sites. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
What are the different types of cookies and how do we use them? Essential – These are Cookies which are essential for the running of our Sites and Services. Without these Cookies, parts of our Sites and Service would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes. Examples of how we may use essential Cookies include:
- Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.
Functional – These Cookies are used to remember your preferences on our Sites and Services and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising. Examples of how we may use functional Cookies include:
- Gathering data about visits to our Sites and Services, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
- Eliminating the need for returning users to re-enter their login details.
Analytical Performance – Analytical performance Cookies are used to monitor the performance of our Sites, for example, to determine the number of page views and the number of unique users our Sites and Services has. We use this information to improve user experience or identify areas of the Sites and Services which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes. Examples of how we may use analytical Cookies include:
- Measuring users’ behavior
- Analyze which pages are viewed and how long for and which links are followed to better develop our Sites and Services
Advertising – Behavioral advertising Cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally. Examples of how we may use advertising Cookies include:
- To market to specific users across our Sites, the Publisher Sites and third party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
Third Party Cookies – You may notice on some pages of our Sites and Services that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these Cookies.
How can you manage or opt-out of cookies?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Sites and the Services. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies If you would like to opt out of Analytics Cookies, please do so by clicking on the links below: Google Analytics: https://tools.google.com/dlpage/gaoptout
Opting out of Behavioral Advertising Cookies If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
HOW YOUR INFORMATION MAY BE USED
We, and our subsidiaries and affiliates (the “Related Companies”), may use the information collected in the following ways:
- To operate and maintain the Sites, Create, Grow or the Video Player;
- To provide and maintain our Services, Create Grow or the Video Player;
- To gather analysis to improve our Services, Create Grow or the Video Player;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- To protect, investigate, and deter against unauthorized or illegal activity.
LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
- Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person
How to File a GDPR Complaint: We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
WHERE YOUR PERSONAL DATA IS HELD: Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party agencies, service providers, representatives and agents as described below (see below: “Third Party Use of Personal Information”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA: To provide the Website or deliver products or services to you, it is necessary for us to share your Personal Data outside the European Economic Area (EEA), eg:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA;
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law. The following countries to which we may transfer Personal Data have been assessed by the European Commission as providing an adequate level of protection for personal information: the United States. Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
THIRD-PARTY USE OF PERSONAL INFORMATION
Mediavine may share your Personal Data with certain third as set forth below:
Third Party Vendors: We may share your information with third party vendors or service providers who help us provide the Services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information
Agents, Consultants, and Related Third Parties: Mediavine, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Mediavine may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Mediavine, (iii) act in urgent circumstances to protect the personal safety of users of the Sites or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts. The Sites currently uses the following third-party service providers:
- Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
- At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.
Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
Non-Identifiable Data: When you interact with Mediavine through the Sites, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Mediavine may store such information itself or such information may be included in databases owned and maintained by Mediavine affiliates, agents, or service providers. The Sites may use such information and pool it with other information to track, for example, the total number of visitors to our Sites, the number of visitors to each page of our Sites, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties. HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT
- We will keep your personal information while you have an account with us or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by law.
- When it is no longer necessary to retain your personal information, we will delete or anonymize it.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information. For the purposes of this section, personal information is used as defined in the CCPA. Mediavine reserves the right to verify all requests made pursuant to the CCPA.
Access and Disclosure You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request. To see any categories of personal information we have sold in the last twelve (12) months, please refer to the section listed above detailing the information we send to our partners.
Deletion Request Rights Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.You have the right to request that Mediavine delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Children Under 16 We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
No Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Rights To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by either (1) calling 888-705-1246; (2) emailing firstname.lastname@example.org or sending us a written request to 160 W. Camino Real #504, Boca Raton, Florida 33432 Attn: CCPA. You may only make a verifiable request for access or disclosure twice within a 12-month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To respond to your request or provide you with personal information, Mediavine must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information Link provided on each Publisher’s website. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at email@example.com. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
Timing We will 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 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
SENSITIVE PERSONAL INFORMATION
Email Communications If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
Last updated: July 22, 2020