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Privacy Policy

Updated: December 2019

Gale Media, Inc. (the “Company,” “we,” or “us”), dba Modern Distribution Management and MDM Analytics, believes you should always know what information we collect from you and how we use it, and that you should have meaningful control over both. This Privacy Policy (“Policy”) describes the privacy practices of the Company, including how it collects and processes your Personal Information you share with us when you access and use our websites, applications, products, events, services and other offerings (“Services”), and the rights and choices available to you regarding such information.

Contents

Overview

What is the lawful basis we use for collecting and using your Personal Information?

How do we collect your Personal Information?

How do we use your Personal Information?

What Personal Information do we automatically collect when you use the Services?

How is your Personal Information shared?

What about children?

What about sensitive data?

How do we transfer your Personal Information?

How do we safeguard your Personal Information?

Where do we store your Personal Information and for how long?

What are your rights?

Notice to California Residents

Who can I contact with questions or concerns?

Overview

We care about the privacy of our subscribers, users of the Services, and users of our applications and connected products and services (collectively, the “Services”). We are fully committed to protecting your Personal Information and use it properly in compliance with data privacy laws. For purposes of this Policy, Personal Information, or Personally Identifiable Information, means information that can be used to directly or indirectly identify you, and may include, but it is not limited to, your name, address, phone number, and email address.

While we strongly urge you to read this Policy, as well as our Terms and Conditions and Cookies Statement from beginning to end, here are some key things we hope you take away:

  • We believe deeply in protecting and managing your Personal Information and privacy. We do not sell, rent, exchange, or transfer your Personal Information to any other company or third party without your consent, unless for the express purpose of delivering the products or services requested, as outlined in this Privacy Policy.
  • We collect and use Personal Information you voluntarily provide to us, such as when you subscribe to MDM Premium or when you use the Company’s Services. The Services may also automatically collect Personal Information. We use this information to improve the Services’ offerings and the user’s experience.
  • To offer the best experience with our websites and Services, we work with various reputable vendors. This means that your Personal Information could be processed by these vendors. If you are a citizen of the European Economic Area (“EEA”), your Personal Information will be transferred to countries outside of the EEA for processing. Data protection and privacy laws in the countries where your Personal Information is transferred may offer a lower level of protection than countries in the EEA.
  • By using our websites and Services, you agree to the Company collecting, using, and transferring (including out of the EEA) your Personal Information.

Please note that this Policy could be updated to reflect changes in the way we handle your Personal Information or any changes in applicable laws. If we make material changes to the Policy, we will provide you notice so you have an opportunity to review the changes.

If you have any questions or concerns regarding this Policy, please contact us at info@mdm.com.

What is our lawful basis for collecting and using your Personal Information?

We collect Personal Information to ensure you receive the best experience with our websites and Services. We only collect Personal Information that you voluntarily agree to provide to us. Your Personal Information will be used: (1) when necessary for the Company’s legitimate interests in carrying out its business, provided that those interests are not outweighed by your rights and interests; (2) when necessary to perform a contract with you; (3) when we have your consent; and (4) when necessary to comply with a legal obligation.

How do we collect your Personal Information?

We collect Personal Information during our normal course of business, as follows:

  • Information you provide to us: We collect Personal Information when you directly provide it to us in the course of your use of the Services; for example, when you subscribe to MDM Premium; register for any of our digital or in-person events; purchase a product or service; sign up for newsletters or promotions; participate in a survey; post comments; and/or otherwise communicate with us or interact with our Services.
  • Information that we receive from third parties: We collect Personal Information when you provide it to third parties we work with by, for example, registering for an event with EventBrite or completing a survey with SurveyMonkey.
  • Information that is automatically collected: We want you to benefit from the information and experience available through the Services. Like many websites, we use web analytics tools that rely on cookies, web beacons, and other automated tracking technologies to help us analyze how users interact with and use the Services, improve the Services, personalize your experience, provide you with information we believe may be of interest to you. For more information on the Services’ automatic Personal Information collection see “What Personal Information do we automatically collect when you use the Services?” in this Policy.

How do we use your Personal Information?

We collect and use your Personal Information for the specific purposes explained in this Policy. Those purposes include:

  • To communicate with you by sending emails, which may include news, updates and information about the Company’s Services when you request them or when we believe they may be of interest to you. You will always have the opportunity to opt-out of receiving communications from the Company or elect to receive only certain communications by following the instructions provided in the email;
  • To provide you with third-party services and products information that we believe may be of interest to you. You will always have the opportunity to opt-out of receiving communications from us or elect to receive only certain communications by following the instructions provided in the email;
  • To process transactions, including payment transactions, when necessary to fulfill orders;
  • To effectively respond to customer service requests and support needs, including responding to inquiries, diagnosing problems with the Site and Services, and other customer care and support;
  • To personalize your experience as your Personal Information helps us better respond to your individual needs;
  • To improve the Services we offer, including maintaining and improving the performance of the Services, developing new features and capabilities, producing effort reports to improve functioning, using search queries and clicks to improve the relevance of your search results and using data to determine what new features to prioritize;
  • To research and analyze the Services’ users’ demographics, interests, and behavior in an aggregated form, including to improve our Services and to improve the Services and its offerings. Where applicable law requires consent to use certain cookies, we will ask for your consent; and
  • For legal, security, safety, and dispute resolution, including detecting and preventing fraud, resolving disputes and enforcing agreements.

We do not sell, rent, exchange, or transfer your Personal Information to any other company or third party without your consent unless for the express purpose of delivering the products or services requested.

We do use third-party vendors to carry out certain services such as website management, hosting, and online purchase and credit card processing. We will only share your Personal Information with third-party vendors that provide services on our behalf for the purposes described in this Policy. In such case, your Personal Information will be shared only for the limited purpose of performing the services on our behalf and under our instruction and in accordance with this Policy.

What Personal Information do we automatically collect when you use the Services?

We collect information about your visit and use of the Services. For example, some of the information is collected using Google Analytics and other third-party analytics tools. The information we collect may include your IP address, your operating system, your browser ID, other information about how you interact with the Services, and your navigation patterns. We use this information to improve our services and the user experience, send you information on product and services we believe may be of interest to you, and for network management and security.

We and Google also use various technologies to collect and store information when you use the Services, including cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the Services, track users’ movement around the Services, and identify ways to improve the Services and determine how we can make the Services a more positive and relevant user experience.

For additional information on how we use cookies and other tracking technologies, as well as how to opt-out of the use of cookies, please see our Cookies Statement. You can reject some or all cookies we use by changing your browser settings. However, doing so can impair the use of the Services or some of its features. For further information about cookies, please visit www.allaboutcookies.org.

How is your Personal Information shared?

Disclosure of Your Information

MDM contracts with other companies to provide certain services on our behalf, including customer service, credit card and billing processing, shipping, subscription fulfillment, research, analytics, list cleansing, postal mailings, email and fax deployment, telemarketing, and other information and business services. We only provide these companies with the relevant information required to perform their services and they are explicitly restricted from using any data received from us for their own marketing purposes.

We may also provide your information to third parties for marketing and/or analytical purposes as further described below:

Sponsors and Gated Resources

From time to time our sponsors wish to contact our subscribers and customers who have indicated an interest in their products, services or events. If you register for or access Services offered by these vendors, you choose to share your name and contact details directly with those vendors so that they may contact you. For example, if you register for a vendor-branded (or co-branded with us) resource, we will collect your registration information on behalf of that vendor for its own use. We may also keep a copy of that data for our own use, consistent with this privacy policy. We may provide a link to the vendor’s privacy policy (as well as to this policy) on the registration page.

Similarly, if you access third-party resources in certain registration-only, or “gated” websites, resource centers, or directory services on our websites, we may share your registration information when you access or click on a link to technical resources provided or sponsored by another company. This includes third-party resources sold through our online stores. In addition, we may share your contact information with sponsors of a particular e-newsletter if you click on their information or offerings. If you do not wish to have your information shared, you will be given an opportunity within the e-newsletter to opt-out.

When you register for an in-person or digital event, we will provide your registration information to the sponsor(s) of such event. We may also provide your information to sponsors of special sessions within the larger event.

Mobile Devices

Mobile marketing campaigns may involve your sending an email from your mobile device to MDM or a third-party campaign operator. An email or other response will then be sent to your mobile device. Opting to participate in this type of campaign is your choice. When you engage in these mobile marketing campaigns, MDM and the third-party campaign operator may collect and use your cell phone number, the name of your wireless service provider, images that you send using your cell phone as part of the campaign, and other relevant information.

Legal Obligation: We reserve the right to share your Personal Information when we believe that such disclosure is necessary to comply with a legal requirement, such as a court order, valid discovery requests, valid subpoena, or to protect the rights or property of the Company, you, or third parties, and if we are acquired in a merger or acquisition.

What about children and our Services?

Neither the websites nor our Services are directed to children. We do not market to, enter into contracts with, or collect Personal Information of any person under 18 years of age. Do not use the websites or the Company’s Services if you are under 18 years of age.

What about sensitive data?

We do not generally collect sensitive data (also known as special categories) through the Services or otherwise. The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offenses (including information about suspected criminal activities).

If you choose to provide us with unsolicited sensitive data, you are consenting to our use of the sensitive data, subject to applicable laws as described in this Policy.

How do we transfer your Personal Information?

We are located in the United States. However, we use service providers and vendors to process Personal Information in the following countries: Canada, Malta, the Netherlands, the United Kingdom, and the United States. Data protection and privacy laws in these countries may offer a lower level of protection than in your country and/or region.

Personal information collected within the EEA will be transferred to countries outside of the EEA for the purposes described in this Policy. We rely on derogations outlined in Article 49 of the General Data Protection Regulation to transfer Personal Information outside of the EEA. In particular, we transfer it out of the EEA with your consent or to perform a contract with you. We apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Policy. By providing your Personal Information to us, you are consenting to the transfer, storing, and processing of your personal information outside of the EEA.

If you are a citizen of the EEA, and you have an unresolved privacy or data concern that we have not addressed satisfactorily, please contact the appropriate EU Data Protection Authority (DPA) free of charge. A list of DPAs can be found here.

How do we safeguard your Personal Information?

We understand that the security of your Personal Information is important. To that end, we maintain organizational, physical, and technical security arrangements for the Personal Information we collect to guard your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.

We restrict access to your Personal Information to those employees of the Company who need to know that information to provide services to you. We train those employees about the importance of confidentiality and maintaining the privacy and security of your information. Service Providers and vendors have access to Personal Information to perform their functions but may not use it for other purposes.

However, despite our efforts, no security controls are 100% effective, and we cannot ensure or warrant the security of the Personal Information you provide to us. There is no guarantee that the data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

The Services may, from time to time, contain links to other websites. If you follow a link to any of these websites, please note that they may have their own privacy policies and that we do not accept any responsibility or liability for these policies or websites. Please check these privacy policies before you submit any Personal Information. This Policy applies only to information collected by the Services and by us and not to other websites that you may link to from here.

We use SSL security on any form that requires credit-card or debit-card information. We will never ask for information that could be used in a phishing scheme without the SSL security behind the form.

Where do we store your Personal Information and for how long?

Your Personal Information is stored on the servers of our service providers and vendors. These are located in Canada, Malta, the Netherlands, the United Kingdom, and the United States.

We will retain your Personal Information for as long as you maintain an account with the Company, or as otherwise necessary to provide you the Company’s Services. We will also retain your Personal Information where necessary to comply with legal obligations, resolve disputes, or enforce agreements. When we no longer need the Personal Information for the purposes outlined in this Policy, we will delete your Personal Information. For more information on where and how long your Personal Information is stored, and for more information on your rights to be forgotten and portability, please contact us at info@mdm.com.

What are your rights?

You may opt-out of our email marketing lists by following the directions at the bottom of our emails. Please note that MDM has a number of brands and products and we allow you to opt-out selectively. To remove a specific email address from all of MDM’s marketing communications, you may send a request info@mdm.com. If you wish to remove your email address only from a specific brand, please use the opt-out mechanism provided in emails you receive from such brand or contact the brand directly.

If you believe the information we have about you needs to be updated, please contact us so we can keep your information accurate. If at any point you wish for MDM to delete information about you, you can simply contact us at info@mdm.com.

You may receive email marketing messages from us about other companies’ offerings as part of a business partner marketing program. To opt-out of a business partner marketing email program, you may follow the instructions at the bottom of any email we send you as part of the program.

You may also receive personalized ads for our products/events while browsing the internet (called “ad retargeting”). To opt out of receiving these personalized ads, the following third-party opt-out tools can be used for that purpose:

—DAA: http://www.aboutads.info/

—NAI: http://optout.networkadvertising.org/?c=1

—EDAA (Europe only): http://www.youronlinechoices.com/

Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”, thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.

Please note that opting-out of promotional mailings will not affect delivery of your subscription-based products.

To remove a specific phone number or fax number from a specific brand’s marketing communications, please follow the opt-out directions provided during/in those communications. To remove a specific phone/fax number from all of MDM’s marketing communications, you may send a request to info@mdm.com.

If you are a resident of the EEA, you have certain rights concerning the collection, use, and storage of your Personal Information. You are entitled to know what Personal Information we collect about you and to have access to that information. You have the right to remove or correct any of your Personal Information that is inaccurate, to object to certain processing, and to withdraw any consent you may have given us for any processing of your personal data. You may also request to have your Personal Information deleted and to have us request that any third-party that has received your Personal Information pursuant to an authorized purpose also cease to use or further disseminate your Personal Information. You can exercise these rights by emailing us at info@mdm.com.

Notice to California Residents

In accordance with the California Consumer Privacy Act (CCPA), this section provides you with specific rights outlined in the legislation and includes information on how to exercise those rights.

Right of Access

You have the right to request that MDM provide you with certain information pertaining to our collection and use of your Personal Information over the past 12 months. Once we receive your verifiable consumer request, we will disclose to you:

  • The categories (and specific pieces) of information MDM has collected about you.
  • The categories of sources for the Personal Information that MDM has collected about you.
  • Our business purpose for collecting and/or selling the Personal Information about you.
  • The categories of third parties with whom we may share that information.
  • If we sold or disclosed your Personal Information for a business purpose, we will disclose to you the categories of your Personal Information that MDM has sold/disclosed.

Right to Deletion

You may also request that MDM delete any Personal Information that we have about you.To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

-Calling us at 1-888-742-5060

-Emailing us at: info@mdm.com

You may only make a verifiable request for access to your Personal Information twice within a 12-month period. In order for MDM to respond to your request or provide you with Personal Information, the verifiable consumer request must:

  • Provide enough information for us to reasonably verify that you are the person about who Personal Information was collected.
  • Include sufficient detail in the description of your request so that we can properly understand, evaluate, and respond to it.

We will only use the Personal Information provided in the verifiable customer request to verify the requestor’s identity.

Right to Non-Discrimination

MDM will not discriminate against you for exercising your CCPA rights. You will not be:

  • Denied goods or services.
  • Charged different pricing/rates for goods and services or suggest that you will be charged different pricing/rates for goods and services.
  • Provided with a sub-standard quality of goods and services or suggest that you will be provided with a sub-standard quality of goods and services.

“Do Not Sell My Personal Information” Request

CCPA law requires that MDM maintain a separate web page where you can choose to opt out of the sale of your Personal Information, which can be accessed by clicking the link below:

https://reports.mdm.com/do-not-sell-my-personal-information/

You may also contact us by phone to make this request by calling 1-888-742-5060.

Categories and Sources of Personal Information Collected

MDM is required by CCPA to provide details of the categories of personal information collected, and the sources of that personal information collection, within the last 12 months (see Information Collection and Automatic Collection Technologies above).

Use of Personal Information

MDM is also required by CCPA to provide details on the purposes of collecting your personal information (see How Do We Use Your Personal Information above).

Information Sold or Disclosed for Business Purposes

MDM has sold the following categories of Personal Information in the last 12 months: Identifiers (contact information) including name, postal address, phone number, email address; and business classifications such as “Company Type”, “Job Title”, and “Job Function”.

Additionally, we utilize trusted third parties to provide services and perform functions for us, including maintenance and hosting, database storage and management, registration processing, and direct marketing campaign processing. Your Personal Information may be shared with these third parties to the extent necessary to provide the services and perform the functions mentioned.

Who can I contact with questions or concerns?

If you have a privacy question, concern, or request, please contact us at: info@mdm.com or at the following address:

Gale Media, Inc.
6309 Monarch Park Place, Suite 201
Niwot, CO 80503

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