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
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|
|Social Media||User Agreement;
Additional Terms for Optional Features
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.
We do not collect the following types of personal information:
We may use the information we collect from you for the following purposes:
Provide our services to our corporate clients and newsletter subscribers:
Communicate with you:
Make improvements to our products and services:
Provide recommendations and deliver relevant advertising:
Investigate theft or other illegal activities and ensure a secure online environment:
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.
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.
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.
California Residents’ Privacy Rights:
Individuals Located in the European Economic Area, the United Kingdom, and Switzerland:
Special Information for Nevada Residents:
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:
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:
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.
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.
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.