Effective Date: January 1, 2020
Last Updated: September 1, 2020
For purposes of European data protection laws, the controller responsible for the described data collection and processing is MRC Media, LLC, 1540 Broadway-32 Floor, New York, New York 10036.
If you are a California resident, see Section 6 for information provided pursuant to the California Consumer Privacy Act.
SECTION 1. We collect information from and about you.
We collect, receive, and develop several different types of personal information about you depending on the nature of your interactions with us:
Contact Information. We may collect your name, email address, phone number and mailing address. If you purchase a digital subscription or create an account, we will collect your username and password. We may collect your social media handles or usernames.
Demographic Information. We may collect demographic information, such as your age, date of birth, or gender.
Location Information. We may automatically collect information about your precise geolocation when you use our apps or access our websites using GPS and WiFi technology. We also collect information about your general location using your IP address and your zip code.
Payment Information. We, or our third-party payment processors, collect your credit card details if you subscribe or make a purchase.
Information you Submit. We collect any information you provide when you contact us or post content.
Purchase and Preference Information. We collect information about your preferences when using our products and services. We collect your order history, such as which subscriptions and products you have purchased or browsed.
Internet and Network Activity Information. For example, we may collect information about the browser you are using and your IP address. We might also collect device identifiers. We use tracking tools like cookies to automatically collect information about how you interact with our websites, apps, and online content, such as your browsing and search history on our sites, what areas of our sites you visit and for how long, what content you click on, what site you came from, what site you visit when you leave us, and your views and clicks of our digital ads and content on other sites.
Employment-Related Information. We, or our third-party vendor, collect information you submit as part of a job application. This may include your work experience and previous employment, your education history, your resume, the URL to your personal or professional websites, and, whether you need a visa to work in the United States. If you apply for a job, you can choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
We collect and develop Inferences. Using the other pieces of personal information collected about you, we draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
SECTION 2. We use information as described here.
We use information to respond to your requests or questions. For example, we may contact you about your account or feedback you have given us. We also use your information to create and administer your account.
We use information to fulfill orders and subscriptions. We use your information to contact you about and fulfill your orders.
We use information to improve our services and products. We may use your information or feedback to make our websites, apps, and services better. We might use your information to customize your experience with us.
We use information to administer our business and services and for internal operations. This might include troubleshooting, data analysis or testing. We might also use information for research, statistical and survey purposes.
We use information for security purposes. We may use information to protect our company or other third parties. These third parties may include other customers or business partners. We also may use information to protect, our websites, apps and our services, as well as to detect and investigate activities that may be illegal or prohibited.
We use information for marketing purposes. For example, we might use your information to tailor and send you information about special promotions or new features or services. We might also use your information to tailor and serve you ads about our products and offers. Our marketing and ads might be for our own offers or products, or for other companies’ offers or products that we think you might find interesting. To learn about your choices for these communications, read the Choices section below.
We use information to communicate with you about your account or our relationship. For example, we might contact you about our policies or our terms, or your participation in a contest or sweepstakes.
We use information for hiring purposes. For example, we use information to review your job applications and contact you about employment opportunities. If you choose to voluntarily submit your ethnicity, gender, disability status, and/or veteran status in connection with a job application, we will use that information for statistical tracking purposes (not for hiring decisions), in accordance with applicable law.
We use information as otherwise disclosed or permitted by law or as we may notify you from time to time.
SECTION 3. We collect information from different sources, directly and indirectly.
We collect information directly from you. For example, we collect information if you sign up for an account or our email list, or place an order. We also collect information if you submit content or otherwise contact us.
We collect information from your devices. We use tracking tools like browser cookies and web beacons to automatically collect information about you when you interact with our websites, our apps, our services, our ads, and our emails that we or our vendors send to you. We collect information about users over time and across devices when you use this website and read our newsletters. We may have third parties collect personal information this way. Learn more about these tools, how we use them and how you can control them, here
We get information from suppliers we hire to work on our behalf. For example, vendors that host or maintain our websites and send promotional emails for us may give us information. Our employment and recruiting vendors also give us information.
We get information from other parties. We work with business and marketing partners. These third parties might also include advertising and analytics providers.
We combine information. For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have.
SECTION 4. We share information with other parties.
We share information within our family of companies. This includes MRC Media, LLC’s subsidiaries, parents, and affiliates.
We share information with suppliers who perform services on our behalf for our business and operational purposes. We may share information with vendors who send emails for us, manage and operate our sites, process payments, fulfill orders, assist us in our marketing and advertising of our products or services, track advertising impressions, provide analytics services, investigate and prevent data incidents, audit our records, vet job applicants, and provide legal advice. We may also share information with analytics and search engine providers.
We share information with our business partners and marketing companies. We might share information with other parties who co-sponsor a promotion. Some of these partners may send you information about products or services by mail or email. We may also share information with other parties, including for the other parties’ own marketing purposes. We may also share with social media platforms, advertising networks, and ad tech companies.
We will share information if we think we have to in order to comply with the law or to protect ourselves, our customers and others. For example, we may share information to respond to a court order or subpoena. We may also share information if a government agency or investigatory body requests it. We might also share your information in order to enforce our agreements, and to protect the rights of others. We might also share information when we are investigating potential fraud. If you are the winner of a sweepstakes or contest, we may also share your information with anyone who requests a winner’s list.
We may share information with a successor to all or part of our business. For example, if part of our business is sold, we may include user information as part of that transaction. We may also share your information if there is a similar change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes.
We may share information for other reasons we may describe to you from time to time as permitted by law.
SECTION 5. You have choices regarding our use of your information.
You can opt out of receiving our e-newsletters and marketing emails. To stop receiving our marketing emails, you can visit your account settings on the site or follow the instructions in any marketing email you get from us. Even if you opt out of getting marketing emails, we will still send you transactional messages. These include responses to your questions or your account registration.
You can contact MRC Media, LLC at firstname.lastname@example.org or by writing to us at MRC Media, LLC, Attn: Privacy, 1540 Broadway, 32nd Floor, New York, New York 10036 to request that we not share your name, postal address, email address, phone number, and certain other personal information with third parties for promotional or marketing purposes.
SECTION 6. Your California Privacy Rights
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry. If you are a California resident, you can also make the following requests with respect to your personal information:
- Access – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling your personal information, the categories of third parties with whom we shared your personal information, and the specific pieces of personal information we collected about you over the past 12 months.
- Deletion – You can request that we delete the personal information that we maintain about you, subject to certain exceptions.
- We collect these categories of personal information from the categories of sources described in Section 3 above.
SECTION 7. Information Transfer and Storage.
Our websites and apps may be operated in the United States and other countries located outside of the European Economic Area (“EEA”). Please be aware that information you provide to us may be transferred to or processed in the United States or other countries located outside of the EEA. The standard of data protection in the United States and in certain other countries where we may process your information is considered by the European Commission to be not adequate when compared to the date protection standards of the EU and EEA. Please also be aware that by using our websites and apps and giving us your information, you consent to such transfer.
SECTION 8. Our sites, services, and products are not intended for children.
We do not knowingly collect personal information from children under 18. If you are a parent or legal guardian and think your child has given us information, you can contact us at email@example.com. You can also write to us at the address listed at the end of this Policy. Please mark your inquiries “Children’s Information Request.”
SECTION 9. Your EU Privacy Rights
As detailed below, where provided under applicable law, you may request information about the personal information about you that we hold, and you may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information, and request the blocking, deletion and portability of such information by contacting us at firstname.lastname@example.org. We may require you to prove your identity with approved identification if you request this information.
Lawful basis for processing your personal data.
We process on the following legal bases:
- Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
- Legitimate Interests: We are permitted to process your personal data if it is based on our legitimate interests. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
- Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
- Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).
Rights of data subjects
You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):
- The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
- The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.
- The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to an EU data protection authority.Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
SECTION 10. We use standard security measures.
SECTION 11. We may link to third party sites or services we don’t control.
SECTION 12. Feel free to contact us if you have more questions.
If you have any questions about this Policy or want to ask us to correct, update, provide access to, delete, or take any other action with respect to your information, please email us at email@example.com. Please do not include your credit card number or other sensitive information in your email. You can also write to us at: MRC Media, LLC Privacy 1540 Broadway-32 FloorNew York, New York 10036Email: firstname.lastname@example.org
SECTION 13. We may update this Policy.
From time to time we may change our privacy policies. We will post an updated copy of our Policy on our website. Please check our site periodically for updates. Your continued use of our website means that you consent to the collection, use and disclosure of your information as set out in the updated Policy. © 2020 MRC Media, LLC. All rights reserved.