Effective: December 23rd, 2019
DemandWorks Media and eBulletins are committed to privacy, data quality, and highly relevant marketing communications that are valued by clients and leads alike. DWM collects personal information about website visitors, subscribers to our eBulletins newsletters, and individuals in their professional capacity (collectively, “you”) to provide our services, which are identification of individuals who may be interested in our clients’ products or services (i.e., lead generation) and providing email newsletters to individuals who sign up to receive them through our eBulletins service.
We disclose your personal information to our clients, which are companies that wish to contact you with marketing communications that are relevant to you in your professional capacity or your company. We may disclose your personal information to our service providers who support our services. We may also disclose your personal information to our partners who assist us with our own online marketing activities. We make options available to you to opt-out of our disclosures to our clients or partners. (But, please be aware that if you opt-out, you may miss out on offers that are relevant to you in your professional capacity or your company.)
To exercise rights that you may have under the law, please contact us at email@example.com.
This Policy applies to DWM and our websites, social media sites and handles, emails we send, and the information we collect when you interact with us. It also applies anywhere it is linked. It does not apply to non-DWM websites and mobile applications that may link to the Sites or be linked to or from the Sites; please review the privacy policies on those websites and applications directly to understand their privacy practices.
We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Sites following the posting of any changes will mean you accept those changes.
If you have questions, contact us at:
444 N. Michigan Avenue, Suite 1200
Chicago, IL 60611
Information We Collect
We collect information that you give us directly, that we capture automatically when you use our Sites, and that we collect from third party sources.
Information you give us: Our Sites enable you to, for example, give us contact and payment information to register an account and buy and sell items, interact with forums and chatrooms, post comments, or submit surveys.
Information we collect automatically: When you interact with the Sites (including when you interact with games that incorporate our software), certain information about your use of our Sites is automatically collected. For example, we track the status of items that you buy and sell, and we collect information about the webpages you view and how you move through our website, how you reached our website, how you interact with our social media pages, and how you interact with our email communications.
Below is a list of our partners who collect information from you on our websites.
|Analytics||Google/Google Tag Manager||Google Privacy and Terms|
|Personalized Advertising||Google/Doubleclick||Google Privacy and Terms|
|Personalized Advertising||AdRoll Roundtrip||Nextroll Privacy Notice|
Information from third party sources: We may collect information about you from our clients and third party sources such as databases that maintain up-to-date business contact information. We collect and use that information in accordance with those sources’ privacy terms.
We also may combine information that we collect from different sources into a single record.
The following is a comprehensive listing of the personal information we collect.
- • Personal Identifiers:
- • We collect your name, business phone number, business email address, and business contact address. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.
- • We collect your social media handle and basic account information when you interact with our Sites through social media.
- • We collect a unique numerical identifier, assigned to you by a cookie we deploy automatically when you use our Sites.
- • We or third parties operating on our behalf collect information about the device you use to access our Sites, such as your IP address, a device ID, and information about your web browser.
- • Commercial Information: When you create an account, such as to receive eBulletins newsletters, we create records about that account.
- • Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites and applications automatically when you use our Sites.
- • Geolocation Data: We collect your IP address automatically when you use our Sites. We or third parties operating on our behalf may be able to determine your general location based on the IP address.
- • Professional or employment-related information: We collect information about your current employer and your employment history.
- • Education information: We collect information about the institutions you have attended and the level of education you have attained.
- • Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We or third parties operating on our behalf may analyze your actual or likely preferences based on the information we gather about you as described above.
We do not collect the following types of personal information:
- • Protected Classifications; Biometric Information; or Audio, electronic, visual, thermal, olfactory, or similar information.
How We Use Information
We may use the information we collect from you for the following purposes:
Provide our services to our corporate clients and newsletter subscribers:
- • Generate leads.
- • Establish and administer your account.
- • Deliver newsletter content.
- • Authenticate access to your account.
- • Perform maintenance and operations, including management of the network and devices supporting the Sites and our systems.
- • Provide technical support and assure quality of customer service interactions.
- • Facilitate hardware and software upgrades for devices and systems.
Communicate with you:
- • Respond to your inquiries.
- • Personalize communications.
- • Send you service-related announcements.
Make improvements to our products and services:
- • Identify and develop new products and services.
- • Understand how our Sites are used.
- • Create measurement and analytics reports.
Provide recommendations and deliver relevant advertising:
- • Market our and our clients’ products and services.
- • Determine which content to recommend to you.
- • Send you promotional communications for the Sites and other products and services we think may be of interest to you.
Investigate theft or other illegal activities and ensure a secure online environment:
- • Detect the unauthorized reception, use, or abuse of the Service.
- • Protect you and other subscribers from fraudulent, abusive, unlawful use of, or subscription to, the Service.
- • Protect our rights, our personnel, and our property.
- • Comply with applicable law.
- • Site Operations/Essential Cookies: To enable features that are necessary for providing you the services on our site, such as identifying you as being signed in, tracking content views, and remembering your preferences.
- • Analytics: To allow us to understand how our services are being used, track site performance and make improvements.
- • Personalized Advertising: To deliver personalized advertising based on your preferences or interests and to measure the effectiveness of ads.
- • Social Media: To enable you to share content from our services through social networks.
How We Share Information
With Service Providers: We may disclose personal information to our service providers, which are companies that process personal data on our behalf. We may disclose your personal information to them without your consent in order to deliver the Service and conduct business activities. We require the service providers to treat the information we disclose to them, or that they collect on our behalf, as confidential and to use the information only for the purposes for which they have been engaged. The following is a list of categories of our service providers.
- • Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status.
- • Auditing and accounting firms.
- • Professional services consultants, such as firms that assist with providing legal services, or supplying project-based resources and assistance.
- • Advertising, marketing, and analytics services, including entities that analyze the information we collect from or about you to communicate with and advertise to you.
- • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- • IT vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operation.
There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.
Our service providers must use the personal information we share with them, or that they collect on our behalf, only for the purposes of our engagement with them.
With Third Parties: We may disclose personal information to third parties. The following is a list of categories of those third parties.
- • DWM Clients: At our clients’ request, we generate lists of leads that may include your business contact information and other information about you in your professional capacity. Our clients use that information to provide you with relevant marketing communications.
- • Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.
- • Advertising, Marketing, and Analytics Partners: We partner with companies that assist us with marketing our Sites and our clients’ products and services, including by “remarketing” to you on other websites, apps, or social media platforms. These companies may collect information from you automatically via cookies or other tracking technologies when you use our Sites.
In this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
The law gives you rights related to your personal information. To make a request to exercise your rights, click here.
Your Rights: Individuals from different countries or jurisdictions may have different rights. We reserve the ability to limit our response to your request to exercise your rights based on the law that is applicable to you, but our goal is to treat everyone equally.
- • Transparency: At the time we collect personal information, you have the right to receive notice of the categories of personal information we collect, and the purposes for which those categories of personal information will be used. This notice should be provided at or before the time of collection.
- • Access/Right to Know: You have the right to request access to personal information we collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it.
- • Correction: You have the right to request that we correct the personal information we hold about you if it is inaccurate or incomplete.
- • Deletion: You have the right to request that we erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.
- • Restrict Processing: You have the right to request that we limit our processing of the personal information we hold about you if we are processing such information based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
- • Opt-Out of Sale: You have the right to request that we stop “selling” your personal information as that that term is defined in the California Consumer Privacy Act. A “sale” of personal information is defined broadly: “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” Please see below for more information about our “sales” of personal information. To opt-out, please see our Do Not Sell My Personal Information page.
California Residents’ Privacy Rights:
- • California “Shine the Light”/Third Party Marketing: Residents of the State of California have the right to request information from DWM regarding other companies to whom DWM has disclosed certain categories of information during the preceding year for those other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please use the contact information provided above.
- • California Consumer Privacy Act (“CCPA”):
- • Categories of personal information we disclose: We may disclose any of the categories of personal information listed above and use them for the above-listed purposes or for other business or operational purposes compatible with the context in which the personal information was collected. Our disclosures of personal information include disclosures to our “service providers,” which are companies that we engage for business purposes to conduct activities on our behalf. The categories of service providers with whom we share information and the services they provide are described above.
- • Categories of personal information we “sell”: We may “sell” the following categories of personal information listed above to third parties: Personal Identifiers (please note that any Personal Identifiers that are disclosed to our clients are limited to your business or professional contact information); Internet or Other Electronic Network Activity Information; and Geolocation Information (only IP address). To opt-out of such sales, please see our Do Not Sell My Personal Information page.
Individuals Located in the European Economic Area, the United Kingdom, and Switzerland:
- • Lawful bases of processing: We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement with you to provide Sites; and (3) as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedoms related to data privacy.
- • Cross-border Transfer: Information we collect may be transferred to, and stored and processed in, the United States or any other country. We use appropriate data transfer mechanisms to lawfully transfer such information.
- • Complaints: Users that reside in the EEA, UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
Special Information for Nevada Residents:
- • Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, DWM does not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please use the contact information provided above.
Options to Control Your Personal Information
Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:
- • Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request; or
- • Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.
If you are a California resident, you may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth of the child certificate in lieu of an affidavit, in order to make requests on the child’s behalf.
We will use the information you provide for verification only for the purpose of verification. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Your Account: Please visit the “Manage My Subscription” page (http://www.ebulletins.com/manage) to update your subscription preferences.
Marketing and Other Communications: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email communication, or email us at firstname.lastname@example.org and we will promptly remove you from all correspondence.
Opt-out of “sale”: You have the right to opt out of our “sale” of personal information to third parties. Please see our Do Not Sell My Personal Information link to make your opt-out request and our description of your rights above.
Cookie Management, Personalized Advertising, and Do Not Track:
- • You can control the cookies on our website using our cookie management settings, here.
- • You can control cookies using your web browser’s settings. If you delete your cookies or if you set your browser to decline cookies, some features of the sites may not be available, work, or work as designed.
- • You can use our partners’ links above to learn more about the options they may make available to opt-out of their tracking technologies.
- • You can broadly opt out of participating companies’ website tracking technologies by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
- • Similarly, you can learn about your options to opt out of mobile app tracking by some advertising networks through your device settings and by resetting the advertiser ID on your mobile device.
When you make an opt-out choice, it does not necessarily mean that you will stop receiving ads altogether, but you will no longer receive personalized ads.
If you delete your cookies, you may also delete your opt-out preferences.
Your browser or device may include “Do Not Track” functionality. At this time, DWM does not respond to browser “Do Not Track” signals.
Other Information about Our Data Processing
Retention: We will retain information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to legal, regulatory or contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.
Security: We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Sites. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies and analytics providers. These other companies will not be able to relate this data to identifiable individuals.
Combination of Information: We may combine information from the Sites together and with other information we obtain from our business records. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.
Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
Cross-border Transfer of Data: If you use our Sites outside of the United States, you understand that we may collect, process, and store your information in the United States and other countries. The laws in the U.S. regarding information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.
Privacy Shield Policy
Last Updated: October 11th 2019
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD NOTICE
DemandWorks Media (DWM) generates business-to-business leads for its clients. To provide this service, DWM may receive personal information.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, DWM or to which DWM discloses personal information for use on DWM’s behalf.
“DemandWorks Media” or “DWM” means DemandWorks Media, LLC and any of its subsidiaries, predecessors and successors in the United States.
“Personal information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal information does not include information that is anonymized or aggregated.
“Sensitive information” means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD PRINCIPLES
DWM receives business contact information such as name, business mailing address, business phone number, and business email address. DWM uses this information on behalf of its clients to identify individuals who may be interested in its clients’ products (i.e., performs lead generation), and to provide email newsletters to individuals who sign up to receive them through its ebulletins service.
DWM will offer EEA and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below.
DWM does not knowingly collect sensitive personal information, and would delete such information immediately if it were discovered.
Data Integrity and Purpose Limitation
DWM will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. DWM will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.
Transfers to Agents
DWM may disclose personal information to Agents, including but not limited to, providers of analytical, hosting, payment processing and other support services. Agents may have access to personal information if needed to perform their functions for DWM. DWM does not transfer personal information to non-Agent third parties.
DWM will require its Agents to safeguard personal information consistent with this Policy by contract obligating the Agent to provide at least the same level of protection as is set forth in this policy.
In certain situations, DWM may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
DWM’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, DWM remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless DWM proves that it is not responsible for the event giving rise to the damage.
Access and Correction
Pursuant to the Privacy Shield Frameworks, EU, the United Kingdom and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information that is deemed to have been processed outside, or in violation of, the Privacy Shield Frameworks. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should contact us at the address given below. If requested to remove data, we will respond within a reasonable timeframe.
DWM will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, DWM is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
DWM will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that DWM determines is in violation of this policy will be subject to disciplinary action.
Dispute Resolution – Privacy Shield
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, DWM commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom and Swiss individuals with Privacy Shield inquiries or complaints should first contact DWM at the address given below. DWM will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.
DWM has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Questions regarding this Policy should be submitted to DWM:
444 N. Michigan Avenue, Suite 1200
Chicago, IL 60611
LIMITATIONS & CHANGES
Adherence by DWM to the EU-U.S. and Swiss-U.S. Privacy Shield Principles may be limited (a) by the exception for personal information that is gathered for publication, broadcast, or other forms of public communication of journalistic material as well as information found in previously published material disseminated from media archives; (b) to the extent required to respond to a legal obligation; (c) to the extent necessary to respond to requests by authorities; and (d) to the extent expressly permitted by an applicable law, rule or regulation.
This Policy may be amended from time to time, consistent with the requirements of the EU-U.S. and Swiss-U.S. Privacy Shield Principles. The amended Policy will be made publicly available via DWM’s website.