XLMedia Plc

XLMEDIA PLC PRIVACY POLICY

Last updated: January 2021.

Effective: January 2021.

This Privacy Policy describes how XLMedia Plc. (“XLMedia”, “we,” “us”) collects, uses, and discloses certain personal information obtained through any of our website: https://www.xlmedia.com/ (the “Site”).  By visiting our Site and/or using the features made available to you on the Site, you are agreeing to the terms of this Policy.  You can jump to particular topics by going to the headings below:

What information we collect and maintain about you

Cookies and Web Log Information

How We Use Your Information

How We Share Your Information with Third Parties

Third-Party Analytics and Advertising

External links

Choice

Data Security

International Users

Data Retention Policy

Children

Changes to This Policy

How to Contact Us

What information we collect and maintain about you

We may collect Personal Information about you when you interact with our Site. “Personal Information” is any information that can be used to identify you or that we can link to you. The following provides examples of the types of information that we collect from you and how we use that information.

Context Types of Data Primary Purpose for Collection
and Use of Data
Account Registration We collect your name and contact information when you create an account.  We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account related functionalities to our users. Accounts can be used, among other things, to save your preference.
Cookies and first party tracking We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our section on Cookies for more information. We obtain consent for cookie collections where required by law.
Cookies and Third Party Tracking We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other website.  See our section on Cookies and Web Log Informationand Web Log Information for more information. We obtain consent for cookie collections where required by law.
Demographic Information We collect personal information, such as your age or location. We have a legitimate interest in understanding our users and providing tailored services.
Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We have a legitimate interest in understanding how you interact with our communications to you.
Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Corporate Partner Information We collect the name, and contact information, of our corporate partners and their employees with whom we may interact. We use information about our corporate partners to perform our with them. This includes communicating with them concerning normal business administration such as projects, services, and billing.
Mailing List When you sign up for one of our mailing lists we collect your email address or postal address. We share information about our products and services with individuals that consent to receive such information.
Partner Promotion We collect information that you provide as part of a co-branded promotion with another company. We have a legitimate interest in fulfilling our promotions.
Surveys When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Sweepstakes, raffles, or contests When you participate in a sweepstakes, raffle, or contest we collect information about you which includes contact information to notify you if you are selected. We have a legitimate interest in operating the sweepstakes.  In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.
Website interactions We use technology to monitor how you interact with our Site. This may include which links you click on, or information that you type into our online forms.  This may also include information about your device or browser. We have a legitimate interest in understanding how you interact with our Site to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.  We also have a legitimate interest in detecting and preventing fraud.
Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our Site.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, data analytics providers, advertising networks, social networks, data brokers, or publicly available sources.

Cookies and Web Log Information

We automatically collect certain Personal Information that does not directly identify you when you use, access, or interact with our Site.  This may include information such as your IP address and domain name, your Internet service provider, the date and time of your visit, your use of the Site during your current session and over time (including the pages you view and the files you download), the URLs from the websites you visit before and after navigating to the Site, your computer’s operating system and browser type, your software and hardware attributes (including device IDs such as IDFA and/or Advertising ID), and your general geographic location (e.g., your city, state, or metropolitan region).  We use the following technologies to automatically collect Personal Information.

  • Web log data.When you visit the Site, we automatically receive and record certain information from your computer (or other device) and your browser.  To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
  • First-party cookies. We also use cookies on the Site.  Cookies are small files that are stored on your computer by your web browser.  A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information.  If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.  You can also delete cookies from your computer.  However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
  • Web beacons. The Site or the emails that you receive from XLMedia may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”).  A web beacon is an electronic file that usually consists of a single-pixel image.  It can be embedded in a web page or in an email to transmit information.  For example, it may allow our email sender to determine whether a user has opened a particular email.

Third-party online tracking and behavioral advertising.  We also may partner with certain third parties to collect, analyze, and use some of the Personal Information described in this section.  For example, we may allow third parties to set cookies or use web beacons or other tracking mechanisms (such as tags or scripts) on the Site or in email communications from us.  This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “Third-Party Analytics and Advertising”).

How We Use Your Information

XLMedia uses the information that we collect for a variety of purposes.  If we have Personal Information about you, we may use it, for example:

  • to respond to your questions or requests concerning the Site or other services offered by us;
  • to fulfill the terms of any agreement you have with us;
  • to fulfill your requests;
  • to send you information about our Site and other topics that are likely to be of interest to you, including surveys, newsletters, updates, or other communications;
  • to deliver notifications and similar operational communications;
  • to improve your user experience and the quality of our Site;
  • to comply with legal and/or regulatory requirements;
  • to manage our business;
  • to count and recognize visitors to the Site and analyzing how visitors use the Site;
  • to improve the Site and enhance users’ experiences with the Site;
  • to create new products and services or improve our existing products and services;
  • to engage in analytics or targeted advertising as described below in the Third-Party Analytics and Advertising section; and
  • for any other business purpose permitted by law, including any purpose for which we use Personal Information.

Consent

Wherever possible, we seek your consent before we collect personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied. Expressed consent can be given orally, electronically or in writing. Implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to receive a publication or providing a name and telephone number to receive a response to a question.

How We Share Your Information with Third Parties

We share your Personal Information with other parties for a variety of purposes, as described below.

Affiliates.  We may share Personal Information with our corporate affiliates for the purposes described in this Policy.

Service providers.  XLMedia uses service providers that perform services on our behalf, including web-hosting companies, emailing vendors, and analytics providers.  These service providers may collect and/or use your Personal Information to assist us in achieving the purposes discussed above.

We may also share your Personal Information with other service providers when necessary to fulfill your requests for services; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Your direct sharing of personal information through the Site or third-party websites and services.  The Site may enable you to share Personal Information with other users of the Site or with websites or online services operated by third parties.  For example, the Site may contain links to third-party websites that incorporate comment and social media features. If you choose to use these features, you may disclose your Personal Information not just to the Site and third-party websites and services, but also to their users and the public more generally.  Because the third-party websites and services are not operated by XLMedia, we are not responsible for the content or practices of those websites or services.  The collection, use, and disclosure of your Personal Information on third-party websites and services will be subject to the privacy policies of the third party websites or services, and not this Policy.

Surveys.  We may ask you to participate in surveys (processed by us or others) that help us understand your use of the Site and improve our advertising.  Any Personal Information provided to us (or supplied by you or us to such external survey providers) in connection with these surveys will only be used in relation to that survey and as stated in this Policy.  Participation in surveys is voluntary.

Third-Party plugins.  The Site may integrate certain third-party plug-ins.  Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view.  They also may set and/or access a cookie.  These plugins are governed by the privacy policy of the company providing them.

Facebook Custom Audiences and Similar Programs.  We may partner with Facebook and other social media partners to deliver advertisements to our users via the Facebook Custom Audiences program or similar third-party programs.  In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address with Facebook or another third-party service.  For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

Legal purposes.  We also may use or share your Personal Information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information.  From time to time, XLMedia may also share aggregated information about Site users, such as by publishing reports on trends in the usage of the Site.

Other Disclosures with Your Consent.  XLMedia may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

Third-Party Analytics and Advertising

Analytics.  We collaborate with certain third parties to collect the Personal Information discussed above and to engage in analysis, auditing, research, and reporting.  These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device.  In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above.  You may opt out of the use of cookies by Google Analytics here.

Advertising.  The Site also enables third-party tracking mechanisms to collect your Personal Information for use in online interest-based advertising.  For example, third parties may use the fact that you visited our Site to target online ads to you.  In addition, our third-party advertising networks might use information about your use of our Site to help target advertisements based on your online activity in general.  For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative webSite or the Digital Advertising Alliance webSite.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this privacy policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies.  Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here.  Please note that opting out of targeted advertising does not opt you out of seeing advertisements.  The advertisements may, however, be less relevant to you.  Our Site currently do not respond to “do not track” browser headers, however you can limit tracking by these third parties by taking the steps discussed above.

The Site contains links to third-party websites. If you follow a link to any of these websites, please note that these websites, and any services that may be accessible through them, have their own privacy policies.  We are not responsible for the privacy practices of other websites.  We encourage our users to be aware when they leave the Site and to read the privacy policies applicable to such third-party websites.  This Privacy Policy applies solely to information collected in connection with the Site.

Choice

You may have certain rights and choices with relation to your personal data, as described below.  

  1. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, news, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.
  2. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
  3. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

 

EEA/UK Residents

If you are located in the EEA or UK, you can make the following choices regarding your Personal Information:

  1. Access To Your Personal Information. You may request access to your Personal Information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing.
  2. Changes To Your Personal Information. We rely on you to update and correct your Personal Information. Most of our websites allow you to modify or delete your account profile.  If our Site does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
  3. Deletion Of Your Personal Information. We retain Personal Information for as long as reasonably necessary to deliver our Site to you, to fulfill the purposes described in this Policy, or as required by law.  You may request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address described below.  If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
  4. Revocation Of Consent. If you revoke your consent for the processing of Personal Information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Please address written requests and questions about your rights to [email protected]

 

Canadian Residents

If you are a resident of Canada, you can make the following choices regarding your Personal

Information:

Correcting Your Personal Information. Canadian residents may have the right to correct or amend personal information in cases where accuracy and completeness is deficient. If required by law we will grant a request to correct or modify your information, but you should note that in many situations we may keep historical information in our backup files as permitted by law.

      California and Canadian Residents

If you are a resident of California or Canada, you can make the following choices regarding your Personal Information:

  1. Access To Your Personal Information. You may request access to your Personal Information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing.
  2. Deletion Of Your Personal Information. California residents may request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address described below.  If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

Note that we do not discriminate against consumers who exercise any of their rights described in this policy. Please address written requests and questions about your rights to [email protected]

As required by law, we will require you to prove your identity if you submit an access request.  We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, email address, or the date of the last email you received from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete Personal Information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

  1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
  2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we employ commercially reasonable physical, technical and administrative procedures to safeguard the Personal Information we collect online.  However, we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk. In the event that we are required by law to inform you of a breach to your Personal Information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

International Users

The Personal Information that we collect through or in connection with the Site may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.  If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the Standard Contractual Clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

Data Retention Policy

We retain personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual requests that we delete information about them and we are required to comply with that request.

Children

Content on this Site is directed at individuals over the age of 18 and is not directed at children under the age of 16. We do not knowingly collect personally identifiable information from children under the age of 16.

Changes to This Policy

XLMedia may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes.  We will post all such changes on the Site, so you should review this page periodically.  If we make a material change to the Policy, you will be provided with appropriate notice.

How to Contact Us

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

Courtyard Suite 21-25 Hart Street Henley-on-Thames, United Kingdom, RG9 2AR

[email protected]

If you are not satisfied with our response, and are in the European Union, you have the right to lodge a complaint with your local supervisory authority.

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California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of Personal Information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law).  We do not “sell” your Personal Information subject to the mentioned in the table below which indicates the categories of Personal Information we collect and transfer in a variety of contexts.  Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.  For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our webSite’s “contact us” page.

Categories of Personal Information We Collect To Whom We Disclose Personal Information for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. ·        Advertising networks

·        Affiliates or subsidiaries

·        Business partners

·        Data analytics providers

·        Government entities, as may be needed to comply with law or prevent illegal activity

·        Internet service providers

·        Joint marketing partners

·        Operating systems and platforms

·        Other Service Providers

·        Payment processors and financial institutions

·        Professional services organizations, this may include auditors and law firms

·        Social networks

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ·        Advertising networks

·        Affiliates or subsidiaries

·        Business partners

·        Data analytics providers

·        Government entities, as may be needed to comply with law or prevent illegal activity

·        Internet service providers

·        Joint marketing partners

·        Operating systems and platforms

·        Other Service Providers

·        Payment processors and financial institutions

·        Professional services organizations, this may include auditors and law firms

·       Social networks

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet webSite, application, or advertisement. ·        Advertising networks

·        Affiliates or subsidiaries

·        Business partners

·        Data analytics providers

·        Government entities, as may be needed to comply with law or prevent illegal activity

·        Internet service providers

·        Joint marketing partners

·        Operating systems and platforms

·        Other Service Providers

·        Payment processors and financial institutions

·        Professional services organizations, this may include auditors and law firms

·       Social networks

Audio, electronic, visual, thermal, olfactory, or similar information ·        Affiliates or subsidiaries

·        Business partners

·        Government entities, as may be needed to comply with law or prevent illegal activity

·        Other Service Providers

·        Professional services organizations, this may include auditors and law firms

Inferences drawn from any of the information listed above ·        Advertising networks

·        Affiliates or subsidiaries

·        Business partners

·        Data analytics providers

·        Government entities, as may be needed to comply with law or prevent illegal activity

·        Internet service providers

·        Joint marketing partners

·        Operating systems and platforms

·        Other Service Providers

·        Payment processors and financial institutions

·        Professional services organizations, this may include auditors and law firms

·       Social networks