Updated and Effective as of January 30, 2023
We will only process your Personal Data in accordance with applicable data protection and privacy laws.
Table of Contents
- Information We Automatically Collect
- Cookies/Tracking Technologies
- Information You Choose To Submit
- Information We Receive From Other Sources
- Information Use
- Social Network and Platform Integration
- Our Information Sharing Practices
- Anonymous Data
- Public Information
- Users Outside of the United States and Consent to Transfer
- How We Respond to “Do Not Track” Signals
- Choice/Opt-Out From Communications
- Retaining, Modifying and Deleting Your Personal Data
- Children’s Privacy
- Sensitive Personal Data
- Important Information for California Residents: Your California Privacy Rights
- Privacy Disclosures for Virginia Residents
- Privacy Disclosures for Nevada Residents
- Privacy Disclosures for European Data Subjects
- Data Subject Request Reporting
- Contact Us
Information We Automatically Collect
Purposes For This Information. We and our third-party service providers use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.
We use tracking technologies, such as cookies, local storage, and pixel tags.
Cookies and Local Storage
We also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the device that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.
We use pixel tags, either provided by us or by our third-party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Pixel tags also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.
A log file is a file that records events that occur in connection with your use of the Service, such as your service use data. We collect log files and other usage information when you access, use and interact with the Services (even if you have not created an account or logged into your account on the Services), including IP address, date and time that you signed up for an account, language setting, browser type, operating system type, internet service provider, referring/exit pages, page you requested, user agent, date and time stamps, clickstream data, and information about your search and click activity.
App Technologies, Customization, and Usage
There are a variety of tracking technologies that may be included in our apps that allow us to collect information about your installation, use, and updating of our apps as well as information about your device, including your unique mobile device identifier (“UDID”) and other technical identifiers. More specifically, these tracking technologies allow us to collect data about your device and your use of our apps, the pages, videos, other content, or ads you see or click on during your visit and when and for how long you do so, and items you download. These tracking technologies are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include third party SDKs, which is code that sends information about your use to a server, and is in effect the app version of a pixel. These SDKs allow us to track our conversions and communicate with you across devices, bring you advertising both on and off the Services, customize the app to your interests and preferences and link such across platforms and devices, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes essential to the operation of our sites and business.
Information You Choose To Submit
In addition, you are required to provide certain Personal Data when you submit a job application and supporting materials. You can also choose to submit or we may collect additional information about yourself, such as demographic information (for example your gender, birth date, or zip code) and information about your preferences and interests. Failure to provide any required Personal Data will prevent us from being able to provide the Services you request (e.g., member registration or submission of job application) or otherwise inhibit our ability to provide the Services.
Here are examples of User Information we may collect:
- Contact Data - your first and last name, email address, postal address, phone number, and other similar contact data.
- Credentials - passwords, password hints, and other information for authentication and account access.
- Demographic Data - demographic information including your age, gender, and country.
- Payment Data - data necessary to process your payment if you make a purchase, including your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. With the exception of partial data such as the last four digits of your credit card, Payment Data will be collected directly by our third-party payment processors, and we will never collect, store, or otherwise process this information.
- Profile Data - your username, interests, favorites, and other profile data.
- Contacts - any contact information that you specifically choose to provide us in order to fulfill a request by you. For example, you may provide us with another person’s name and address in order to fulfill a gift subscription for that person. Such functionality is only intended for United States residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
- Content - the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use.
- Resume Data - to consider you for a job opening if you submit an application to us, including your employment history, writing samples, and references.
- Survey Data - we may also survey visitors about various topics, including events and experiences, media consumption preferences and how we can improve our Services. Response to our surveys is entirely voluntary.
- Public Postings - information when you submit something to be displayed on our Services. Any communication you submit or that may be posted to a publicly viewable area of our Services, such as a comment on an article or a review, is a public communication and may be viewed by the general public. Therefore, you acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to such areas via our Services, whether or not your submission includes Personal Data. These submissions would include newsletter sign-ups and any area of our Service that requires a login or registration prior to use. If at any time you display your Personal Data in any communication submitted to such areas, other individuals may collect and use your Personal Data. We are not responsible for, nor can we guarantee the protection of, any Personal Data you disclose in a communication submitted to such areas for posting or contained in an email or other communication submitted to us for such posting, and thus, you acknowledge that if you disclose Personal Data in any such material, you do so at your own risk.
Information We Receive From Other Sources
- Advertising and analytics data: We may receive various types of Personal Data and Usage Data from our third-party partners and vendors, such as analytics data about your visits to our Services, reporting information about ad campaigns, information about your browsing behavior, interests or preferences, and contact information (such as email address). For example, third parties who provide advertising and related services (such as analytics providers and ad networks) may provide us with information that we can compare it to Personal Data we hold in order to determine if you are the same individual (one method of doing this is called “cookie-matching”).
- Purchases: We may receive Personal Data about you from third parties when you buy things through our Services or when you buy things from a third party after clicking on an affiliate link in our content. This information may include your contact details (such as name and email address) and financial and other details related to the transaction (such as items purchased and purchase price) from providers of technical, payment and delivery services.
- Referrals: Your Personal Data may be provided by other users of the Services (for example, if your email address is entered into the Services by a friend referring you to the Services).
- Third-party connections: If you use a third-party connection or log-in (such as Facebook Connect or Google) in connection with the Services, we may receive your name, email address and/or profile photo from those third-party services or other information available about you or collected from you on those services.
- Other sources: We may also supplement the Personal Data we collect from you with other information from third parties, including third-party vendors, affiliate network operators, referral sources, social networking sites or services (such as Facebook), and publicly-available sources.
We use the information we collect, including Personal Data and Usage Data:
- to enable you to use our Services, to process information you provide via our Services (including verifying that your email address is active and valid), and to process your transactions;
- to create an account or profile and share certain information about yourself with other users through your account or profile;
- connect you across multiple devices or platforms where you are accessing our content;
- to provide related customer service and care, including responding to your questions, complaints, or comments, and sending surveys and processing survey responses;
- to send you notices, updates, security alerts, and other support and administrative messages, including SMS text message mobile alerts for specific purposes;
- process transactions and send you any related information;
- to provide you with information, products, or services that you have requested;
- to offer a feature that allows visitors to send a link to another person to inform them about an article or feature on the Services. We do not retain telephone numbers or email addresses collected for these purposes after sending the SMS text message or email;
- to receive and process job applications for jobs with us;
- to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third-party partners;
- to personalize the Services and tailor content, recommendations, and advertisements we and third parties display to you, both on the Services and elsewhere online;
- for internal business purposes, such as to improve our Services and content;
- to monitor and analyze how our Services are used;
- to detect, investigate and/or prevent fraudulent, unauthorized, or illegal activity; maintain the security of our Services, including for age verification purposes; enforce the various terms and conditions for our Services; and protect the rights, property, and/or safety of you, us, or others;
- to comply with regulatory and legal obligations; and
Social Network and Platform Integration
Our Information Sharing Practice
Our Events and promotions may be jointly managed, sponsored or offered by third parties. If you voluntarily choose to enter or attend an Event, we may share your information with third parties as set forth in the official rules that govern the Event as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a contest or sweepstakes Event, you agree to the official rules that govern that Event, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. Some events may be managed wholly by a third party and will be governed by any rules or terms they provide for that event and it is your responsibility to review and comply with those terms.
Third-Party Direct Marketing
Third Party Features
When you submit a photo to Twinning, we post a composite image of your photo and your celebrity look-a-likes on a public URL for you to reference and share with your friends. When you submit a photo to Aura by POPSUGAR, we post an image of your photo with your results on a public URL. For both Twinning and Aura by POPSUGAR, while we only provide this unique URL to you. The URL is public and may be viewed by anyone who has the link. You can request removal of any unique URL created in connection with your photos through Twinning or Aura by POPSUGAR by contacting us at email@example.com.
We take no responsibility for the content or privacy practices of any third parties. We encourage you to carefully review the privacy policies of any third-party services you access.
Change of Control
Other Disclosure Scenarios
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third-party. We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data will include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name or other personal identifiers) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.
If you identify any User Information as public, you are authorizing us to share such information publicly. For example, you can elect to make certain of your User Submissions (such as your alias, bio, email or photos) publicly available. Also, there are areas of the Services (for example, message boards, discussion rooms, and other online forums) in which you are able to post information that automatically will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone can access, use, and disclose any information that you post to those areas.
Users Outside of the United States and Consent to Transfer
How We Respond to “Do Not Track” Signals
Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit.
Except as required by applicable law, the Services do not alter their practices when they receive a “Do Not Track” signal automatically from a visitor’s browser. To find out more about “Do Not Track,” please visit here.
We use other companies under agreements with us to serve third-party advertisements when you visit and use the Services. These companies may collect and use clickstream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one. In addition, we share with these third parties any Personal Data you voluntarily provide, such as an email address, in response to an advertisement or sponsored content link.
In order to serve offers and advertisements that may be of interest to our users, we display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected.
Your Ad Choices
Some of the third-party services providers and/or Advertisers may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). You can visit here, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You can opt-out of the use of your behavioral data used by DAA members to serve you interest-based advertising on third-party sites here.
If you are accessing the Services through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device’s application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information, visit here.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.
Choice/Opt-Out From Communications
Retaining, Modifying and Deleting Your Personal Data
You may request access to the information you have provided to us. If you wish to make a request, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us, please let us know by logging in and updating your profile. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law, for necessary operational reasons, or to maintain uniform business practices.
We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below.
The Services contain links to other websites that we do not control, and the Services contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third-party. We may also integrate with third parties who will interact with you under their terms of service.
We especially care about the privacy of young children. Most of our Services, with the exception of certain child-directed services as described below, are intended for a general audience and are not intended for and should not be used by children under the age of 16. We do not knowingly collect information from children under the age of 16 on our general audience services, and we do not target such services to children under the age of 16.
Some of our Services are clearly identified as being marketed directly to children under the age of 16 (such as our Dodo Kids channel or other child-directed services). In connection with such child-directed services, we do not knowingly collect any Personal Data from users under the age of 16 without complying with applicable legal requirements and making appropriate disclosures. We are committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”), a U.S. federal law designed to protect children online. We may collect and store persistent identifiers (such as IP addresses) from children without parental consent for the purpose of supporting the internal operations of the Services or as otherwise permitted under COPPA.
For any of our Services, if a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
When we conduct research or carry out surveys and you participate in our research or surveys, we may collect sensitive Personal Data about you, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will get your explicit consent for our collection, use, or sharing of this data where required by law. Otherwise, we ask that you not send us, and you not disclose, any sensitive Personal Data as this term is defined under applicable data protection and privacy laws on or through the Services or otherwise to us.
Important Information for California Residents: Your California Privacy Rights
We collect information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “Personal Information.” If you are a California consumer, as defined by the CCPA, the CCPA provides you with specific rights regarding your Personal Information. This section describes the rights that California consumers have and explains how to exercise those rights. For the purposes of this section, Personal Information does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA. To be clear, these rights are granted only to the extent that you are a California consumer. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA with respect to the applicable Personal Information.
Information We Collect; How We Collect It; How We Use It
Information about our data collection during the prior 12 months is described below. California consumers may access, delete, and control certain uses of their information as set forth in Rights to Your Information.
Purposes for Which Such Information Was Collected in the Preceding 12 Months or Will be Used
Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12 Months or will be Collected
Categories of Third Parties With Whom the Website Shares Personal Information
Disclosed by Company in the Preceding Twelve (12) Months for a Business Purpose
"Shared" or "Sold" (as defined by CCPA) by Company in the Preceding Twelve (12) Months
A. Personal identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
See Sections 1-6
See Sections 1-6
See Section 7
Personally Identifiable Information such as government ID numbers, names or addresses are not sold or shared, but technical identifiers such as unique IDs, technical identifiers, and behavioral actions associated therewith may be sold and shared. Occasionally, we may “sell” or “share” names and email addresses with sponsors of events or sweepstakes, but will notify you separately upon participation in those activities.
B. Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Some personal information included in this category may overlap with other categories.
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
See Sections 1-6
See Sections 1-6
See Section 7
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
See Sections 1-6
See Sections 1-6
See Section 7
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
See Sections 1-6
See Sections 1-6
See Section 7
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
See Sections 1-6
See Sections 1-6
See Section 7
G. Location data.
Physical location or movements.
See Sections 1-6
See Sections 1-6
See Section 7
DMA level location data may be “sold” or “shared” for targeting of advertising to specific areas, but not specific location.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
See Sections 1-6
See Sections 1-6
See Section 7
I. Professional or employment-related information.
Current or past job history or performance evaluations.
See Sections 1-6
See Sections 1-6
See Section 7
K. Inferences drawn from other personal information for profiling purposes.
Used to create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
See Sections 1-6
See Sections 1-6
See Section 7
Sharing of Personal Information
We may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your right to opt out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below). The information above under Information We Collect; How We Collect It; How We Use It describes the third parties with which we may share your Personal Information.
Right to Know and Delete
If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
Right to Know About Personal Information Collected, Disclosed or Sold
As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights, below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:
- The categories of Personal Information we collected about you.
- The categories of sources from which the Personal Information is collected.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- Deletion Request Rights
- Exercising Access and Deletion Rights
- Personal Information Sales Opt-Out and Opt-In Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights, below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. However, we may retain Personal Information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
To exercise any of these rights, please submit a request through our online form or email us at firstname.lastname@example.org. Alternatively, you may contact us with the details of your request at the following toll-free phone number: 1-800-478-9140. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days.
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above.
We have a duty as the holder of certain personal information to verify your identity when making requests to know or delete personal information and to ensure that dissemination of that information would not cause harm to you if it were distributed to another person. To verify your identity, we will request and collect additional personal information from you to match it against our records. We may ask for additional information or documentation if we feel it is necessary to confirm your identity with the necessary degree of certainty. We may communicate with you through email, a secure message center, or other reasonably necessary and appropriate means. We do have the right to deny requests under certain circumstances. In such cases, we will notify you of the reasons for denial.
You have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 16 and less than 16 years of age, or the parent or guardian of a consumer less than 16 years of age. To our knowledge, we do not sell the Personal Information of minors under 16 years of age.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page: "Do Not Sell or Share My Personal Information." You may also submit a request to opt-out by emailing us at email@example.com.
You may change your mind and opt back in to Personal Information sales at any time by emailing us at firstname.lastname@example.org.
We will not discriminate against you for exercising any of your CCPA rights, including but not limited to, by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.
We may offer discounted prices to consumers who sign up to be on our mailing lists or join our loyalty programs. Such programs will have additional terms that require your review and agreement. Please review those terms for the details of those programs, how to withdraw or cancel, or to assert your rights specific to those programs.
We generally do not treat consumers differently if they exercise a right under California law. However, in certain circumstances, discounted prices will require you to be on our mailing list or a member of our loyalty program. In such circumstances, we may offer a price difference because the price is reasonably related to the value of your data. The value of your data will be explained in the terms of such incentivized programs.
Shine the Light
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing.
To exercise a Shine the Light request, please contact us at email@example.com or Bill Simmons Media Group c/o Legal Department , 438 N Gower St, Los Angeles, CA 90028. You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone, email, or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.
Privacy Disclosures for Virginia Residents
The Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers with specific rights regarding their Personal Data. To the extent that you are a resident of Virginia, this section describes your rights under the VCDPA and explains how you may exercise these rights.
Rights to Your Information
- Right to know. You have the right to know whether we process your Personal Data and to access such Personal Data.
- Right to data portability. You have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such Personal Data up to twice annually, subject to certain exceptions.
- Right to delete. You have the right to delete Personal Data that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the VCDPA. Additionally, if you request deletion of your Personal Data and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your Personal Data remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such Personal Data for any purpose except for those allowed under the VCDPA.
- We DO process Personal Data for the purposes of targeted advertising;
- We DO NOT sell your Personal Data in exchange for monetary consideration; and
- We DO NOT engage in profiling decision based on your Personal Data that produce legal or similarly significant effects concerning you.
If you wish to opt out of the processing of your Personal Data for any of the above purposes, please submit a request here.
- Right to correct. You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes for which we process it.
- Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your Virginia privacy rights. Unless permitted by the VCDPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How to Exercise Your Rights; Verifying Your Identity
To exercise any of your Virginia privacy rights, or if you have any questions about your privacy rights, you may contact us by emailing us at firstname.lastname@example.org.
After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.
Only you may make a verifiable request related to your Personal Data. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s Personal Data, we may ask you to submit reliable proof of your identity.
Response Time; Your Right to Appeal
We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the VCDPA allows us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.
If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. You will have the right to appeal within a reasonable period of time after you have received our decision. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting the Virginia Attorney General to submit a complaint.
Privacy Disclosures for Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us here or email us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
Privacy Disclosures for European Data Subjects
IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
We will only use your personal data, as that term is defined under the General Data Protection Regulation or comparable local law in the United Kingdom or Switzerland (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have consented to a certain use of your personal data.
- Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary.
Vox is the data controller of all personal data collected through our Services. To contact us, please see the section titled Contact Us.
If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager can be contacted at: firstname.lastname@example.org.
Provision of personal data and failure to provide personal data:
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.
Collection of personal data from third-party sources:
We may obtain personal data and other information about you through public sources and/or our third-party partners who help us provide our products and services to you.
Withdrawing your consent:
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at email@example.com.
We may transfer personal data from the EEA, Switzerland, and the UK to the United States and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain service providers, we may use specific contracts approved by the European Commission and/or UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at firstname.lastname@example.org.
Use of your personal data for marketing purposes:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your personal data for marketing purposes.
Data Subject Rights:
If you are situated in the EEA, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To exercise your rights under the GDPR, please contact us at email@example.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have. For more information about how to get access to Personal Data and for exercising your rights, you can submit a request here by selecting the “I am an EU resident and would like to exercise my individual rights” option.
Data Subject Request Reporting
You can find a summary of our data subject reporting here, detailing the following for the past calendar year:
- The number of requests to know that Vox received, complied with in whole or in part, and denied;
- The number of requests to delete that the Vox received, complied with in whole or in part, and denied;
- The number of requests to opt-out that the Vox received, complied with in whole or in part, and denied; and
- The median or mean number of days within which the Vox substantively responded to requests to know, requests to delete, and requests to opt-out.