Last Updated: October 2023
Effective: October 2023
This policy is issued on behalf of the XLMedia plc group of companies (collectively “XLMedia”) therefore when we mention “XLMedia”, “we”, “us” or “our” in this policy, we are referring to the relevant company in the XLMedia group responsible for processing your data.
XLMedia Publishing Limited (a subsidiary company of XLMedia plc) is the controller and responsible for the Site.
By visiting the Site and/or using the features made available to you on the Site, you are agreeing to the terms and conditions of this policy.
Personal Information we may collect and maintain about you
We may collect Personal Information (as defined below) about you when you interact with the Site.
“Personal Information” is any information that can be used to identify you or that we can link to you. The following table sets out examples of the types of Personal Information that we may collect from you and how we may use that Personal Information.
|Context||Types of Data||Primary Purpose for Collection and Use of Data|
|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.|
|Employment:||If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.||We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.|
|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 work 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 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.|
|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.|
|Site interactions||We use technology to monitor how you interact with the 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 the Site in order to 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 the Site. Among other things, it helps us understand which of our services is the most popular.|
When you choose to use a service on the Site, you will be directed to a third party website where you can provide the information required to become one of their customers. XLMedia does not collect or receive the information you input on that third party 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 the Site. This may include information such as your IP address and domain name, your internet service provider, the date and time of your visit to the Site, 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 recognise your computer and gather information about its online activity.
- Clear gif / 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 behavioural advertising. We may partner with certain third parties to collect, analyse, 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 behavioural advertising, as discussed below (see the section entitled “Third-Party Analytics and Advertising”).
How We Use Your Information
XLMedia uses the Personal Information that we collect for a variety of purposes. If we hold Personal Information about you, we may use it, for example to:
- provide a service to you;
- respond to your questions or requests concerning the Site or other services offered or provided by us;
- fulfil the terms of any agreement you have with us;
- fulfil your requests;
- send you information about the Site and other topics that are likely to be of interest to you, including surveys, newsletters, updates, or other communications;
- deliver notifications and similar operational communications;
- improve your user experience and the quality of our Site;
- comply with legal and/or regulatory requirements;
- manage our business;
- count and recognise visitors to the Site and analyse how visitors use the Site;
- improve the Site and enhance users’ experiences with the Site;
- create new services or improve our existing services;
- 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.
How We Share Your Information with Third Parties
We may 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 fulfil 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 permit comments to be submitted on articles and contain links to third-party websites that incorporate comment and social media features. The Site may also contain Facebook “like” buttons and Twitter “follow” buttons and may contain similar features of other third parties. 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. Please note that because the third-party websites and services are not operated by XLMedia we are not responsible for and accept no liability 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.
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;
- 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;
- establish, protect, or exercise our legal rights or defend against legal claims; or
- 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 the Site users, such as by publishing reports on trends in the usage of the Site or interest in the types of services featured on the Site.
Other Disclosures with Your Consent. XLMedia may ask if you would like us to share your Personal Information with other unaffiliated third parties who are not described elsewhere in this policy.
Third-Party Analytics and Advertising
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 the Site to target online ads to you. In addition, our third-party advertising networks might use information about your use of the 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 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 or liable 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 policy applies solely to Personal Information collected in connection with the Site.
You may have certain rights and choices in relation to your Personal Information, as described below.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, 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 emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
- 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.”
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
If you are located in the EEA, Switzerland or the UK, you can make the following choices regarding your Personal Information:
- 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 hold about you.
- Changes To Your Personal Information & Cookie Preferences. We rely on you to update and correct your Personal Information and your cookie preferences. Most of our websites (including the Site) allow you to modify or delete your account profile and your cookie preferences. If the Site does not permit you to update or correct certain information, please contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our back-up files as permitted by law.
- Deletion Of Your Personal Information. We retain Personal Information for as long as reasonably necessary to make the Site available to you, to fulfil 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 Personal 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.
- Revocation Of Consent. If you revoke your consent for the processing of Personal Information then we may no longer be able to provide you a product or service. 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 of your Personal Information (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].
If you are located in California, you can make the following choices regarding your Personal Information:
- Access To Your Personal Information. You have a right to request disclosure of and 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 hold 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.
- Correction or Deletion Of Your Personal Information. You may request information about how long we keep a specific type of Personal Information, or request that we correct or delete your Personal Information by contacting us at the address described below. If required by law, we will grant a request to delete Personal 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.
- The Right to Opt-Out. You may request that we not sell or share your Personal Information at the email address below.
In some circumstances, you may designate an authorised agent (for example, an attorney) to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorised 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 authorised agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorised agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
- 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.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal 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 Personal Information you transmit to the Site or to us, and you transmit any Personal 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.
Where We Store Your Personal Information and International Users
Data Retention Policy
We retain Personal Information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual requests that we delete Personal Information about them and we are required to comply with that request.
Content on this Site is directed at and intended for individuals over the age of 18 and is not directed at or intended for children under the age of 16. We do not knowingly collect personally identifiable information from individuals under the age of 18.
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 [email protected]. We will attempt to respond to your requests and to provide you with additional privacy-related information.
If you are not satisfied with our response and are resident in the EEA, Switzerland or the UK you have the right to lodge a complaint with your local supervisory authority.
California Information Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organisations 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|
|Commercial information – this may include information about services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Advertising 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|
|Audio, electronic, visual, thermal, olfactory, or similar information.||Affiliates or subsidiaries|
|Inferences drawn from any of the information listed above.||Advertising networks|