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PRIVACY POLICY Last Updated: December 30, 2019
This privacy policy (“Policy”) describes how Engaged Media, LLC and its related companies (“Company”) collect, use and share personal information of consumer users of any of our websites that post this Policy or incorporate this Policy into their Terms of Service (each is referred to in this Policy as the “Site”). This Policy does not apply to websites that specifically post different privacy policies.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us. We collect your name, postal address, email address, phone number, location, username, password, demographic information (such as your age, gender, occupation), third party social media profile information, as well as other information you directly give us on our Site. If you elect to purchase products or services through our Site, we will collect the payment information that you provide to facilitate the transaction.
Information We Get From Others. We may get information about you from other sources. We may add this to information we get from this Site. If you register or log into your Account using a third party authenticator login (such as Facebook), you authorize us to access certain account information from the third party authenticator, such as your public profile (consistent with the third party’s privacy policy and your privacy settings related thereto), email address, interests, “likes,” gender, birthday, education history, work history, interests, current city, photos, videos, personal description, friend list, and other information from your use of the third party service. Information we get from others (including third party data companies) may be combined with information you give us.
Location Information. When you use the Site, we may collect your location information from your device. This location information may include your longitudinal and latitudinal coordinates. If you do not agree to this collection, you can change your privacy preferences on your device, but the some functionality of the Site may be disabled.
Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times, and information about your use of and actions on our Site.
Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
Google Analytics. We also use Google Analytics to understand how the site is being used. Google Analytics uses permanent cookies on your web browser to identify you as a unique user. All data are anonymous. Please review the Google Privacy pages for more information: https://www.google.com/policies/privacy/
USE OF PERSONAL INFORMATION
We know it is important to protect your personal data under the EU Regulation 2016/679 General Data Protection Regulation (GDPR), CASL, CCPA & CAN-SPAM and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy.
You provide us with your data for us to do this
We collect data from you to do this
When you browse our website we may collect anonymous data relating to how you use our website. We use this to maintain and improve our website and the service we provide to you.
We use data that you provide to us and data we collect from you to do this
When you agree to take a service or product from us: through purchasing, registering, logging into, authenticating or accessing your account. We use this data to fulfil the service to you.
You fill in a form on our website (contact us, buy, request a demo etc.) We use this data to respond to your requests.
Providing us with information about others
If you provide information to us on behalf of someone else, you confirm that you have provided them with the information set out in this privacy policy and that they have not objected to such use of their personal data. You must make sure that you have the right and permission to use their information in this way. By providing the information you confirm that you have the permission and right to do so.
Types of data that we collect
Contact details
This may include your first name, last name, telephone numbers (mobile or landline), email address, company details…
Data that identifies you
Your IP address (mostly anonymised), browser type and version, time zone setting, browser plug-in types, geolocation data (your location in the world), operating system and version…
Data on how you use Engaged Media Mags
Your URL clickstreams (the path you take through our website), pages viewed, page response times, website errors, download errors, the time that you spend on our website, how you navigate our website and use it, how often you use it…
Children’s data: Engaged Media Mags is a business service directed at adults and for use in business. We do not target children and we do not knowingly collect any personal data from children, any person under 16 years of age. If you are not 16 years of age or above you may not use our service or software. If our algorithms or staff validate your age to be below 16 years we will disable your account.
How and why we use your data
The GDPR describes how we can use your data and the legal basis to do so. This is how and why we use your data:
Legal basis is defined as follows:
Contract: this is necessary to fulfil the contract that you have with us or necessary to fulfil the procedures prior to entering the contract.
Consent: you have given consent for us to process your data for that specific purpose.
Legitimate interest: this is necessary for our legitimate interests or legitimate interests of a third party. These may include to gain insights from your conduct on our website, to provide our service and products to you, to improve and develop our services, communication and support, to determine the effectiveness of our marketing, to enhance our data security.
We use your personal information to:
SHARING OF PERSONAL INFORMATION
We may share personal information as follows:
We may also share aggregated and/or anonymized data with others for their own uses.
You can change your consent preferences at any time. This means that you can give consent and withdraw consent whenever you want to. You can contact us at info@engagedmediamags.com or update your consent preferences at www.engagedmediamags.com
.
Your privacy choices
You can choose not to provide us with your personal data (you will still be able to visit our website however, we will not be able to provide you with our products and services).
You can disable cookies in your browser (you can continue to visit our website, however, the website may not work as effectively or optimally).
You can choose that we do not use your personal data for marketing purposes (we will ask you before we use your personal data for marketing purposes and you can always opt-in or opt-out by contacting us or by updating your preferences on our website).
Your Privacy Rights
The GDPR sets out the following rights applicable to data subjects. You can exercise your rights by contacting us at info@engagedmediamags.com
The right to access
You have the right to access your personal data that we hold about you.
You can contact Engaged Media Mags requesting this information via a subject access request (SAR) free of charge.
The subject access request should be made by email info@engagedmediamags.com Engaged Media Mags will verify the individual making the subject access request before handing over the information.
Engaged Media Mags will aim to respond to such a request in, usually, one month of receipt but this may be extended if the SAR is complex. We will keep you informed of the progress.
The right to be informed
We aim to keep you informed of how your information is collected, processed, transferred, and stored. This includes:
The purpose for collecting the information at the time of collection
Information collected for communication purposes, at the time of the first communication
Transfer of data to another party, before transfer or as soon as reasonably possible
Transfer of information to a third party located outside of the EMI
The right to rectification
We aim to keep the personal data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate personal data about you, we will delete it or correct it promptly. Please email us at info@galaxkey.com. Our systems enable our users to update their information if required.
The right to erasure (also known as the ‘right to be forgotten’)
You can request that your personal data that Engaged Media Mags holds about you be erased. Engaged Media Mags will erase personal data in accordance with the GDPR. Unless Engaged Media Mags has reasonable grounds to refuse the erasure, all requests will be complied with.
INFORMATION CHOICES AND CHANGES
Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
EXTERNAL LINKS
Links to third-party websites from this website are provided as a convenience to you. If you use these links, you will leave this site. We do not assume responsibility for any of these sites, their content, or their privacy policies.
SECURITY
On the Site, we may use secure socket layer technology (SSL), which is designed to encrypt the transmission of information shared between your browser and our site. Where SSL is being used, a padlock icon will appear adjacent to the URL in your browser. Click on the padlock next to the URL to view certificate details. If you do not see the padlock, we may not have implemented SSL on the Site, or there could be an issue with your browser or the secure socket layer technology.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
DATA RETENTION
Even after you delete your account, copies of information you have submitted to the site, such as survey responses, may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed by others, or it was copied or stored by other users. You may not have the authority or ability to remove information (including survey responses) you submitted by participating in the site.
CORPORATE EVENTS
If we become involved in a merger, acquisition, or any form of sale of some or all of its assets, your information may be included in the assets sold or transferred to the acquirer. You hereby agree that we may transfer or assign the information we have collected from you in connection with any such event. In the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of creditors, we may not be able to control how your personal information is treated, transferred or used.
LOCATION OF SERVERS
Our servers are located in the United States of America. If you are accessing the site and service from outside the United States, please be advised that through your continued use of the site or service, which is governed by U.S. law and this Privacy Policy, you are transferring your personal information to the United States and you consent to that transfer and the maintenance and processing of such information in the United States.
INFORMATION OF CHILDREN
This site is not intended for use by minors under the age of 13. If we learn that a child under the age of 13 has provided us with personal information without verifiable parental consent, we will promptly take reasonable and appropriate actions to remove such user and delete any personal information from our servers.
CONTACT INFORMATION. We welcome your comments or questions about this privacy policy. You may also contact us at:
Privacy Inquiries Engaged Media, LLC 3622 Lyckan Parkway Suite 3003 Durham, NC 27707 support@engagedmedia.com
CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will change the Last Updated date above.
Engaged Media LLC, whose registered office is at 3622 Lyckan Parkway Suite 3003, Durham, NC 27707 know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly.
Our privacy policy forms part of our website terms and conditions. You should read this policy in conjunction with our website terms.
By accepting our website terms or by visiting www.engagedmediamags.com you are accepting and consenting to the practices described in this privacy policy.
If you are an Engaged Media LLC customer or subscriber, or just visiting our website, this policy applies to you.
This privacy policy explains:
o Creation or administration of your account. This personal data may include name, usernames, email address, phone number, physical address, company name, payment details
o Information that you provide when you contact us
o Information that you provide when you access our products and services
o Information that you provide through consents and preference updates
We know it is important to protect your personal data under the EU Regulation 2016/679 General Data Protection Regulation (GDPR) and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy.
Engaged Media LLC as a data controller
If you are a registered Engaged Media LLC user/customer or a visitor to our website we act as the data controller of personal data. This means that we decide how and why we process your data.
Engaged Media LLC as a data processor
If you are agreeing a contract through Engaged Media LLC, you should check the privacy policy of the Engaged Media LLC customer who sent you the contract. This means that you are not the registered user and we act as the data processor of the Engaged Media LLC customer who has sent you the contract. This means we only process your data to help us provide our service to our customer, or in accordance with our customer’s instructions, or as required by law. Our customer is responsible to ensure that your personal data is handled in accordance with the data protection laws, including how service providers (like Engaged Media LLC), collect and use data on their behalf.
From the first time you interact with Engaged Media LLC, we may collect data. This includes you giving us your data directly and us collecting data from you or third-party sources which may be collected automatically.
Data on how you use Engaged Media LLC
Children’s data
Engaged Media LLC is a business service directed at adults and for use in business. We do not target children and we do not knowingly collect any personal data from children, any person under 16 years of age. If you are not 16 years of age or above you may not use our service or software. If our algorithms or staff validate your age to be below 16 years we will disable your account.
To maintain Engaged Media LLC functioning properly and compliantly
Legal basis: contract and legitimate interest
To maintain and improve Engaged Media LLC
Customer support
Legal basis: contract
Marketing
Legal basis: consent
You can contact Engaged Media LLC requesting this information via a subject access request (SAR) free of charge.
The subject access request should be made by email to info@engagedmediamags.com. Engaged Media LLC will verify the individual making the subject access request before handing over the information.
Engaged Media LLC will aim to respond to such a request in, usually, one month of receipt but this may be extended if the SAR is complex. We will keep you informed of the progress.
We aim to keep the personal data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate personal data about you, we will delete it or correct it promptly. Please email us at info@engagedmediamags.com. . Our systems enable our users to update their information if required.
You can request that your personal data that Engaged Media LLC holds about you be erased. Engaged Media LLC will erase personal data in accordance with the GDPR. Unless Engaged Media LLC has reasonable grounds to refuse the erasure, all requests will be complied with.
The right to restrict processing
You can request that Engaged Media LLC stops the processing of your data. Engaged Media LLC will comply and will only retain the personal data (if any) necessary to ensure that the information is no longer processed by Engaged Media LLC
The right to data portability
Engaged Media LLC ensures the portability of your data. To facilitate data portability Engaged Media LLC will make the personal data available in a Engaged Media LLC encrypted format that is securely transferable to you on request. This will be complied with in a timely manner.
The right to object
You can object to Engaged Media LLC processing your personal data based on legitimate interests, direct marketing, processing for scientific and/or historical research and statistic purposes. Unless the law allows, Engaged Media LLC will comply with your request and stop processing your information.
The Rights with respect to automated decision-making and profiling
Engaged Media LLC does not use personal data for automated decision making and profiling.
We have organisational and technical measures in place to protect your data and secure the information that you provide, and we collect. We take steps to ensure personal data collected, held, and processed is kept secure and protected from unauthorised or unlawful processing and against accidental loss, destruction or damage.
We protect the security of your information during transmission by using Secure Sockets Layer (SSL) or TLS (Transport Layer Security) and with Engaged Media LLC software which encrypts information you input with your key. So, we don’t have access to your data that you secure using Engaged Media LLC, only you do and those you give access to.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data.
Our security procedures mean that we may occasionally request proof of identity before we disclose personal data to you.
It is important for you to protect your Engaged Media LLC account against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
We also provide free 2 Factor and or Multifactor authentication which we recommend you always use to protect your account and thus your protected Engaged Media LLC data. You may not share your password or credentials with anyone, doing so is against our terms of service and will lead to account closure.
It is important to remember that the information you provide on our website is your choice and no transmission is 100% guaranteed secure, especially as it traverses a public network which we have no control over.
Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control. If you require better security please use Engaged Media LLC
You are solely responsible for your credentials, your username and password. Do not share these details and keep them private and secure
If you believe your privacy has been breached, let us know by contacting us immediately at info@engagedmediamags.com.
The personal data that we collect is mainly processed in our offices in London and in any data processing facilities operated by third parties identified in this policy.
We may employ third-parties to perform functions on our behalf and may share your personal data to these parties to fulfil our function and contract including: for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service.
Those parties are bound by strict contractual provisions with us and only have access to personal data needed to perform their functions and may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Policy and as permitted by the data protection regulation
We may transfer your encrypted data if we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal data held by us, about our customers, will be one of the transferred assets.
We may transfer your data if applicable by law. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
To operate effectively we may need to transfer data to third parties outside the EEA. By submitting your personal data, you agree to this transfer, storing and processing by us. If we transfer or store your data outside of the EEA, we will ensure that the transfer is subject to appropriate safeguards so that your security and privacy is maintained.
Engaged Media LLC will only keep personal data for the amount of time that it is needed for the original processing purpose. If it is no longer needed, Engaged Media LLC will take reasonable steps to securely remove the information.
To ensure that personal data is kept for no longer than is necessary, Engaged Media LLC has a data retention period of 12 months if the user is not active or after the expiration of the subscription. Unless agreed otherwise with you in a separate contract. We remove information securely by digital shredding.
We sometimes use third parties to help us provide the Engaged Media LLC products and services to you. The third parties that we partner with are chosen by us, they adhere to the data protection regulation and this privacy policy.
We may need to share your data with these third parties to fulfil our function and contract with you. We only do this is if it is necessary and when we do we have safeguards in place to protect your data and your privacy as outlined in this policy. Below are our main third-party processing partners and links to their privacy policies. These partners do not have access to any of the data content you have protected with Engaged Media LLC software.
Third party
Purpose
Data collected or shared
Privacy Policy
We use cookies on our website. Our cookies are used to improve your website experience. You can choose to disable the cookies in your browser. Please see our Cookie Policy for further details.
Please be aware that the Engaged Media LLC website may link to other websites that may be accessed by you through our site. We are not responsible for their data security and privacy policies, content or security of these linked websites. We do not have any control over how these linked third parties may use your data when you when you choose to purchase products or services or otherwise to contact them via our site.
We do not provide any personal data to these third-party websites.
We exclude all liability for loss that you may incur when using these third-party websites.
If you have any complaints or questions relating to your privacy or this policy please contact us at info@engagedmediamags.com.
We may update this policy from time to time so please check back on a regular basis. If we make any significant changes we will notify you through our software or by email. If you have any questions relating to your privacy or this policy please contact us at info@engagedmediamags.com.
This policy is governed by the law of the US. These terms and all of the subject matter are solely governed by US and not for the country in which the Engaged Media LLC licensed services, software, services and web infrastructure is purchased, installed and used.
Any dispute will be handled exclusively in the jurisdiction of the courts of US.
If you would like any more information or you have any comments about our privacy policy, please either write to us at Data Protection Manager, Engaged Media LLC 3622 Lyckan Parkway Suite 3003, Durham, NC 27707 or email us at info@engagedmediamags.com.
You can ask us for a copy of this privacy policy and of any amended privacy policy by writing to the above address or by emailing us at info@engagedmediamags.com.
Any use of our systems for illegal activities will result in immediate suspension of your account.
YOUR CALIFORNIA PRIVACY RIGHTS
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. To make such a request, please contact us: 17900 Sky Park Circle, Suite 220, Irvine, CA – 92614 | Contact Us | Email: ccpa@engaged.media
We do not support Do Not Track browser settings and do not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personally Identifiable Information or Non Personally Identifiable Information.
The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services.
You may exercise your right to know and your right to deletion twice a year free of charge.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
Children
We do not and will not knowingly collect information from any unsupervised child under the age of 13. If you are under the age of 13, you may not use the Services unless your parent or guardian has provided us with their consent for your use of the Services.
