1. Information We Collect, and How We Collect It
Information That You Provide
We collect information and personal information that you provide in connection with the Site and Network Websites. The categories of information we collect can include:
- Registration information. We collect personal information that you provide when you register on a Site or Network Website, such as for a subscription or membership. If you use a social media or other third party service account to register, this information may include your name, user ID, profile picture, and other profile information that the social media account or third party service shares with us. If you do not use a social media or other third party service account to register, and you register directly with the Site or Network Website, we may collect information such as your name, username, email address, password, and other information you provide.
- Paid subscriptions and memberships. If you sign up for a paid subscription or membership, we and/or our service providers may collect your payment information.
- Mailing List Information. We will collect your email address if you provide it through a Site or Network Website, such as to receive newsletters, updates, or promotions.
- Inquiries and Feedback. If you contact us, we will collect the information that you provide us, such as your contact information and the contents of your communication with us.
Information from Third Parties
We also collect and receive information about you from third parties, including the following:
- Information we receive from social networking sites. When you interact with the Site or Network Websites through social media websites and services like Facebook, such as when you login to the Site or Network Websites using your social media credentials, share content from the Site or Network Websites with your social media accounts, use plugins or widgets we may receive information from those websites and services. The information we receive may include your public profile information, profile picture, user name, user ID associated with your social media account, email address, and any other information you permit the social media website or service to share with us or third parties generally. The data we receive may depend upon your privacy settings with the social media website or service, though we do not control those settings or promise they will be effective. You should always review and customize your privacy settings with social media websites and services before linking or connecting them to our Site or the Network Websites.
- Information we receive from third parties. We may receive information about you from third parties like Krux (www.krux.com) and other companies like ad networks, data brokers, and others that sell or license data about people. This information may include demographic data (age range, gender, etc.), interests (e.g. shopping categories or topics of interest), ZIP Code or other similar location level data, IP addresses or unique device identifiers, and other information that they make available. We may also collect information about you from public records or that is otherwise publicly available.
Information That Is Automatically Collected (Cookies and Other Technologies)
We also automatically collect information about you and any computer or device you use to access the Site, Network Websites, or websites that use the Program. Some of the information we collect, and ways we collect it, on the Site, Network Websites, and websites that use the Program include:
- Cookies. We may send one or more cookies — small text files containing a string of alphanumeric characters — to your computer or device that allows us to uniquely identify your browser, computer, or device. A cookie may also convey other information to us, such as your Internet Protocol (“IP”) address, unique device identifiers, your browser settings and specifications, and information about how you use the Site, Network Websites, or websites that use the Program (e.g., the pages you view, the links you click, how frequently you access it, and other actions you take on it). Cookies also allow us to track your usage of the Site, Network Websites, and websites that use the Program over time.
- Scripts. We may use scripts—short segments of computer code included in a web page or other content that can be used to set and access a cookie on your computer and to record your activity on a website.
- Log Files. We may record log file information which may include information such as your web request, IP address, browser type, unique device identifiers, information about your device, referring / exit pages and URLs, number of clicks and how you interact with links, domain names, landing pages, pages viewed, and other such information.
- Clear GIFs and Click-Stream Data. We may employ clear GIFs (also known as web beacons or pixel tags) which may collect information about you, your computer or device such as your web request, IP address, unique device identifiers, browser type, information about your device, pages viewed, and information about cookies, all of which can show your usage patterns for the Site, Network Websites, and websites that use the Program. We also use clear GIFs in conjunction with cookies to collect click-stream data which allows us to understand how visitors move from page to page within websites.
- Mobile Device Information, Identifiers and Location Data. When you use a mobile device, we may collect and store a unique identifier associated with your device (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. A unique identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by Say Media. A unique identifier may convey information to us about how you browse the Site, Network Websites, or websites that use the Program. A unique identifier may remain persistently on your device, and some features of the Say Media Services may not function properly if use or availability of unique identifiers or location data are impaired or disabled.
When you visit third party sites that use the Program, those third parties or other third parties may automatically collect information about you and any computer or device you use to access such sites, and this Policy does not describe the information collection or use practices that occur on those sites (other than our practices with respect to the Program).
2. Information Third Parties Collect
When you visit the Site or Network Websites third parties may obtain information about you or your computer or device. These third parties may include:
- Service Providers. We may use service providers to help with the Site or Network Websites or any other lawful activity may do, including the other activities we describe under this Policy. This means service providers may collect, process, and store any of the information that we may collect under the Policy, and information collected in connection with the Site or Network Websites may be collected directly by our service providers. For example, we may use service providers to help us process payments, store information we collect, facilitate interaction with the Site or Network Websites such as in forums or comments, and receive and transmit emails and communications.
- Third Party Tracking and Online Advertising. Third party ad networks, social media companies, and other third party services may collect information about you, your computer or device when you visit or use the Site and Network Websites. This information may be collected automatically, including through cookies, social media plug-ins, and other technologies. The information collected, and manner in which it is collected, may include the information and methods described in the “Information That Is Automatically Collected (Cookies and Other Technologies)” section above. These third parties may collect information about your use of the Site and Network Websites over time, and they may combine it with other information that they possess or obtain about you, such as about your use of other websites and services. These third parties may use this information for our or for third party purposes, including commercial purposes such as tailoring advertising to you on the Site and Network Websites or in other locations like third party websites and services. Some examples of third parties that we use include the following: (1) Google Analytics, which may use technologies like clear gifs and cookies to collect information, including for our and for Google’s own purposes. Google wants us to provide you with a link to its webpage “How Google uses data when you use our partners’ sites or apps” at https://www.google.com/policies/privacy/partners/; and (2) DoubleClick, which may use technologies like clear gifs, cookies, and its Audience Management tags, to collect information, including for our and for DoubleClick and Google’s own purposes. Additional DoubleClick privacy information is available at https://www.google.com/intl/en/policies/privacy/. For information about choices that you may have about this information collection and use, see the “Your Choices” Section below.
When you visit third party sites that use the Program, those third parties or other third parties may collect information about you or your computer or device, and this Policy does not describe the information collection or use practices that occur on those sites (other than our practices with respect to the Program).
3. How We Use Information
We collect, use, process, combine, retain and store information and personal information that we collect or receive for a variety of purposes, including the following:
- For our business activities, including to operate, maintain, and provide the features and functionality of the Site and Say Media Services;
- To track your preferences, and to maintain your account and subscription;
- To process your payments (e.g., for subscriptions);
- To communicate with you and respond to your requests, such as to respond to your questions, contact you about changes to the Site or Network Websites, account-related matters, or other matters related to the Site or Network Websites;
- To provide you with customized or personalized content or information on the Site or Say Media Services;
- For marketing and advertising purposes, such as to market to you or offer you our and third party special offers or other products or services we think that you may be interested in;
- To track analytics and use of the Site and Say Media Services;
- To monitor the effectiveness of our Site and Say Media Services features and functionality;
- To monitor and prevent fraud and abuse, enforce this Policy, to resolve disputes, and otherwise to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
- To comply with contractual and legal obligations and requirements;
- To fulfill any other purpose for which you provide personal information; and
- For any other lawful purpose, or other purpose that you consent to.
Some Network Websites may offer the ability to sign up for a premium account that allows you to visit those Network Websites without, or with limited, advertisements (a “Premium Account”). If you use a Premium Account for a particular Network Website that supports Premium Accounts, we will not use personal information about you for advertising purposes. If you choose to click on an advertisement, to follow a link to an advertisement or advertiser’s website, or to provide information to an advertiser, the advertiser’s privacy policies, and not this Policy, apply, and personal information may be collected from you.
4. Sharing of Information
We also transmit, disclose, grant access to, make available, and provide (“Disclose”) personal information to third parties, including:
- To service providers, subcontractors, partners, vendors, consultants, and others that help us with any of the purposes noted above or otherwise in this Policy;
- To our affiliates, parent companies, subsidiaries, and other related companies, all for the purposes noted above or otherwise in this Policy;
- To third parties that the Network Websites relate to, or that contain advertisements as part of the Program, including for marketing and advertising purposes;
- To third parties for our or third party research, marketing and advertising (including online advertising) purposes;
- To third parties to respond or comply with, in our sole discretion, a court order, subpoena, law enforcement or other government request (with or without notice to you, in our discretion);
- To buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us may be among the assets transferred;
- To other third parties with your consent or upon your consent; and
- To third parties, in our discretion, to: (i) satisfy any applicable law or regulation, (ii) enforce this Policy, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, or (iv) protect against harm to the rights, property or safety of us, the Site or Network Websites or their users, or third parties.
We also will Disclose information that does not constitute personal information to third parties for the purposes noted above, as well as for other purposes in our sole discretion.
If you use a Premium Account for a particular Network Website, we will not share personal information about you with third parties for advertising purposes.
We do not control third parties’ use of information or personal information. If you do not want us to Disclose personal information to third parties, please do not use the Site or Network Websites.
5. Information Access and Correction
If you have registered for an account on the Site or Network Websites, we may provide you with the ability to access, review and change certain personal information by logging into your account and using the features and functionalities available there.
Not all personal information is maintained in a format that you can access or change. If you would like to request access to, or correction or deletion of personal information, you may send your request to us at email@example.com. We will review your request, and may require you to provide additional information to identify yourself, but we do not promise that we will be able to satisfy your request. For example, the personal information may already have been relied or acted upon, or disclosed to third parties, and we generally do not take steps (or have the ability to take steps) to undo prior reliance or actions. We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or if doing so would be burdensome in our discretion.
6. Your Choices
We strive to give you choices about how your personal information is collected and used. For example, you can decline to provide certain types personal information to Say Media or you can stop using the Site and Network Websites, which may limit your use of the Site and Network Websites. We also provide you with the following choices:
- Program Online Advertising. If you do not want Say Media to use information about you to tailor advertising that we deliver in connection with the Program, visit the Say Media opt-out page for instructions and details about the opt-out: http://www.saymedia.com/fine-print.
- Other Online Advertising. You may be able to opt-out of other types of online advertising-related cookies used at the Site and Network Websites by actively managing the settings on your browser or mobile device, but we do not promise that such settings will be effective. Please refer to your browser’s or mobile device’s technical information for information on the settings offered for cookies or other tracking technologies. You also may be able to opt-out of some online-advertising related cookies: at the Digital Advertising Alliance’s Consumer Choice Opt-Out pages at http://www.aboutads.info/choices and http://www.aboutads.info/choices-mobile (for mobile devices); at the Network Advertising Initiative consumer opt-out page at http://www.networkadvertising.org/choices/; for Krux by following the instructions at http://www.krux.com/privacy/consumer-choice/; and for Disqus (a third party we may use on the Site and Network Websites for comments) using the options at https://help.disqus.com/customer/portal/articles/1657951. To learn more about cookies, you may wish to visit https://www.consumer.ftc.gov/articles/0042-cookies-leaving-trail-web.
7. Do Not Track Preferences
While we want to honor your privacy as described in this Policy, unfortunately the Site and Network Websites do not monitor for or behave differently if your computer or browser transmits a “do not track” or similar message to us, the Site, or Network Websites.
8. Data Protection
We take what we believe to be commercially reasonable steps to help protect personal information that we collect, but we do not guarantee that personal information will be completely protected. For example, the transmission of information via the Internet is not completely secure. Any transmission of personal information by you is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Network Websites, including the illegal acts of third parties (such as criminal hacking).
The safety and security of your information also depends on you. Where you have chosen account credentials (e.g., user names and passwords) for access to certain parts of the Site or Network Websites, you are responsible for keeping those credentials confidential. Do not give your credentials to anyone else. If you enter a section of the Site or Network Websites that requires a password, you should log out when you leave. If you believe that any account credentials for the Site or Network Websites have been compromised, please contact us immediately at firstname.lastname@example.org.
9. Data Retention
We tend to keep personal information for as long as we deem necessary for our business purposes, or as otherwise required to operate the Site or Say Media Services, comply with your requests, or comply with applicable law.
10. Information From Children
The Site and Say Media Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13, and believe that your child may have provided us with personal information, please contact us at email@example.com, and we will use commercially reasonable efforts to delete that information.
11. Third Party Websites
The Site and Say Media Services may include links to third party websites and online services. This Policy does not describe the privacy practices of those websites or services. Please review the privacy policies of those websites or services before providing personal information to them.
12. Updates to This Policy
We may amend this Policy from time to time. When we do so, we will update the “Last Revision Date” at the end of the Policy. Your continued use of the Site or Network Websites after an updated Policy is posted constitutes your consent to the revised Policy.
13. Governing Law
This Policy is governed by the laws of the State of California and the United States of America.
14. Contacting Us
If have questions about this Policy or our privacy practices, please contact us at firstname.lastname@example.org.
15. Last Revision Date
This Policy was last revised on August 30, 2016.