MediaPRO Privacy Policy

Last modified: December 2019

Introduction

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.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use Our Services. By accessing or using Our Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of Our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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;
  • Username;
  • Password;
  • Company;
  • Department;
  • 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:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of Our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to Our Services.
  • 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.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use Our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

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.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • 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.
  • To enforce or apply our terms of use https://www.mediapro.com/terms-of-service/ or under our MediaPRO Services Agreement or sales order, or similar agreement for use of our services, and other agreements, including for billing and collection purposes.
  • 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:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • 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 itsec@mediapro.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 itsec@mediapro.com 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.

Data Security

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.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on Our Services home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on Our Services home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting Our Services and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

itsec@mediapro.com

GDPR Privacy Rights Addendum

The provisions below are intended to provide transparency into the data processing activities of MediaPRO Holdings LLC and to identify Data Subjects’ rights as they pertain to our collection, processing, storage, sharing and retention policies in compliance with Regulation 2016/679 of the European Parliament and of 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”); and any other similar data protection laws in any other applicable territory, each as amended, replaced, or superseded GDPR.  This GDPR Privacy Rights Addendum is intended to supplement our Privacy Policy and the terms should be read in conjunction with each other.

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: itsec@mediapro.com).  Our phone number is 425-483-4700.

Purpose of Our Processing of Personal Data:

As more fully described in our Privacy Policy, we collect the following information for purposes:

  • 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?

As set forth in our general Privacy Policy, we may share collected personal information 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
  • By informing us by e-mail, post or phone using the contact details set out in the Privacy Policy.

Do we use cookies?

Please see our cookie policy in the Privacy Policy.  For more information on third-party advertising-related cookies and how to exercise your choice to opt-out of them, please visit www.aboutads.info/choices and/or www.networkadvertising.org/choices/.  Further general information about cookies and how they work is available at www.allaboutcookies.org.

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:
  1. 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
  2. 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

California Privacy Rights Addendum

Effective Date: January 1, 2020

Last Reviewed on: December 31, 2019

This Privacy Notice for California Residents supplements the information contained in MediaPRO’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.]

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected
A. 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. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 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.

Some personal information included in this category may overlap with other categories.

YES
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).

 

YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you use such as our training courses or that may be purchased by your company.
  • Indirectly from you. For example, from observing your actions on our Website.
  • From social media marketing.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users/consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting 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).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request 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, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you will need to submit a signed declaration indicating that you are designating an individual as your agent. We may also ask the agent to verify their own identity prior to processing their request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • Full Name
    • E-mail Address
    • Home Address
    • Telephone Number
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We may require that you submit a personal signed declaration if you are requesting access to or deletion of sensitive personal information.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to MediaPRO@privacysupportservices.com.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which MediaPRO Holdings, LLC collects and uses your information described here and in the company Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (877) 566-1077

Email: MediaPRO@privacysupportservices.com

Postal Address:

See Privacy Policy