Last modified: November 2019
MediaPRO Holdings, LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit Our Services www.mediapro.com or use MediaPRO’s Services as defined in the MediaPRO Services Agreement (MediaPRO Services, the website and any shall be referred to as “Our Services“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- To perform Our Services.
- To perform customer or technical services related to Our Services.
- In email, text, and other electronic messages between you and the Company or our contractors, agents or affiliated third-parties.
- Through mobile and desktop applications you download from Our Services, which provide dedicated non-browser-based interaction between you and Our Services.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy:
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on Our Services.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of Our Services, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number and any information you submit to us online and any other identifier by which you may be contacted online or offline (“personal information“);
- That is about you but individually does not identify you, such as company name, title/position, work e-mail, work telephone/fax number; and/or
- About your internet connection, the equipment you use to access Our Services, and usage details.
We collect this information:
- Directly from you when you provide it to us;
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies;
- From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through Our Services may include:
- Information that you provide by filling in forms on Our Services. This includes information provided at the time of registering to use and subscribe to Our Services, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with Our Services;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Your responses to surveys that we might ask you to complete for research purposes;
- Details of transactions you carry out through Our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through Our Services;
- Your search queries on Our Services.
What specific information is collected?
For registered users and users/customers, including users of free trials, we collect the following data:
- Full name;
- Email address;
- IP address.
For users affirmatively allow their domains to be ‘white-listed’ for USB Campaigns we collect:
- Machine name;
- Mac address;
- IP address;
For LMS users we collect:
- Phone number;
- Physical address;
- Chat username;
- Data provided in custom field where users may enter any data desired.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with Our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to Our Services, including traffic data, geolocation data (for Internet Service Provider (“ISP”), logs, and other communication data and the resources that you access and use on Our Services.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact us for information on how you can opt out of behavioral tracking on Our Services and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve Our Services, our services and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize Our Services according to your individual interests;
- Speed up your searches;
- Recognize you when you return to Our Services.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of Our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on Our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our Our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
We contract with these third parties and they may use tracking technologies and dictate how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present Our Services and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your services, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to Our Services or any products or services we offer or provide though it.
- To allow you to participate in interactive features on Our Services or our services.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that we have the rights to offer that may be of interest to you. If you do not want us to use your information in this way, please contact us. For more information, see Choices About How We Use and Disclose Your Information.
Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and the provision of our services.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MediaPRO Holdings, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MediaPRO Holdings, LLC about Our Services users is among the assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MediaPRO Services, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into Our Services and adjusting your user preferences in your account profile, checking or unchecking the relevant boxes or by sending us an email with your request to email@example.com.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by contacting us at the email address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email to our contact information below.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
MediaPRO does not sell your data which may trigger additional opt-out requirements in the U.S. and abroad.
Accessing and Correcting Your Information
You can review and change your personal information by logging into Our Services and visiting your account profile page.
You may also send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights below for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit California Privacy Rights Addendum.
Your European Union GDPR Privacy Rights
If you are a European Union citizen residing in Europe you may be entitled to additional rights as set forth in the General Regulation of the European Parliament and the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR). As such you may be considered a “Data Subject” and we may be deemed a ‘Data Controller’ or ‘Processor’ as such terms are defined in the GDPR. Please visit GDPR Privacy Rights Addendum for an understanding of your additional GDPR rights related to your use of Our Services and our performance of services to you which may result in the processing of your personal information.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and any information deemed sensitive shall be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of Our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of Our Services like message boards. The information you share in public areas may be viewed by any user of Our Services.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to Our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on Our Services.
GDPR Privacy Rights Addendum
Who we Are and How to Contact Us:
We are MediaPRO Holdings, LLC, our business address is 20021 120th Ave NE, Bothell, WA 98011 Suite 101. We have appointed a Data Protection Leader: Jerome Gotz (email: email@example.com). Our phone number is 425-483-4700.
Purpose of Our Processing of Personal Data:
- Performance and fulfillment of Our Services
- To perform customer or technical services related to Our Services
- Electronic messaging between you and the Company including our contractors, agents or affiliated third-parties.
- Interaction with our Website or Mobile App
- Advertisements During visits to Our Website or interaction with Our Services
Legal Basis for the Processing of Personal Data:
We process your data in order to fulfill our obligations to you to perform the services and to tell you about additional opportunities and services that we may provide, as such we have a legitimate interest. The following is additional information related to the legal basis for our collection:
- Performance and fulfillment of Our Services: It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
- To perform customer or technical services related to Our Services: It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
- Electronic messaging between you and the Company including our contractors, agents or affiliated third-parties. It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
- Interaction with our Website or Mobile App. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
- Advertisements During visits to Our Website or interaction with Our Services: Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Who do we share your data with?
- Our subsidiaries and affiliates.
- Contractors, service providers, and other third parties that we use to support our business and the provision of our services.
- To a buyer acquiring or in the process of acquiring all or part of MediaPRO Holdings, LLC’s assets.
Will we share your data outside of the European Union?
Where necessary we will transfer personal information to countries outside of the European Union to MediaPRO’s United States based servers. When we transfer your information outside of the European Union we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. If transferred, your information will be stored in the United States on our secure servers. We will share your data with third-party companies only in the United States and in your local European Union countries or regions and solely to perform the services that you have requested.
How long will we keep your information?
We will keep your information for as long as necessary to perform the requested services or fulfill the need for your data as required above in the section entitled What is the purpose that we collect your data? After performance of the services we will keep the data pursuant to our data retention policy only for archival purposes.
How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
- Through your employer’s acknowledgment of consent to collect its employees’ information such as names, titles, emails and phone numbers in order for our performance of Our Services for and on behalf of your company;
- At the time we collect your personal information following the instructions provided; or
Do we protect your personal information?
Yes. We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration. We have implemented information security policies and guidelines, rules and technical measures to protect the personal information that we have under our control from:
- Unauthorised access;
- Improper use or disclosure;
- Unauthorised modification; and
- Unlawful destruction or accidental loss.
All of our members, employees, workers and data processors (those that may process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors and users of Our Services.
How to Access Your Information and Your Other Rights?
You may have the following rights in relation to the personal information we hold about you depending on the applicable data privacy laws in your home country:
Your right of access.
- If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
- If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
- You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing.
- You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
- With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
- You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling.
- You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
- If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to your local Information Commissioner’s Office (ICO). You can find details about how to do this for example on the ICO website for the UK at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113 or your other applicable local countries’ similar offices