Last updated to address California Consumer Privacy Act of 2018 and effective as of January 17, 2020.
PART 1: INFORMATION WE COLLECT AND HOW WE USE IT
Lotame collects usage data (“Usage Data”) via cookies, web beacons and similar technologies as further described in the Tracking Technologies section below. Usage Data includes information about our visitors and how they use our Websites, including browser type, the website you were visiting before you visited the Websites, time of day and your IP address, your mobile device advertising identifier and similar device identifiers. We use Usage Data for a variety of purposes, including to improve our Websites and services.
PART 2: TRACKING TECHNOLOGIES
“Cookies” and local storage are pieces of information (data files) transferred to a browser when the user visits a site. These technologies are able to store a unique identifier for a device to allow an online service provider to recognize the device whenever the device is used to visit the site. You can find more information about cookies and how they work at www.allaboutcookies.org.
Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1×1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
PART 3: SOCIAL NETWORK AND PLATFORM INTEGRATION, AND THIRD PARTY LINKS
The Websites may contain integration with social networks and other platforms. For example, the Websites may contain buttons that direct users to our social networking pages (such as Facebook or Twitter) or enabling you to “like” or “share” the Websites’ content to other online services. If you choose to “like” or “share” content or to otherwise post information via the Websites to a third-party website or other online service, that information may be publicly displayed and the third-party website may have access to information about you and your use of our Websites.
In addition, the Websites may have links to third party websites. If you click on social networking buttons or third party links, you will be taken to those third parties websites, and your use of those third parties’ websites and platforms are subject to their privacy policies and practices. We are not responsible for the privacy or business practices of any third party.
PART 4: INFORMATION THIRD PARTIES PROVIDE ABOUT YOU
PART 5: HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
In addition, if you apply for a job through the Websites, Lotame may ask you to provide self-identifying information (such as veteran status, gender and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”) and other federal, state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, Lotame or its service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.
PART 6: THIRD-PARTY ANALYTICS PROVIDERS, AD SERVERS, AND SIMILAR THIRD PARTIES
In addition to Lotame performing its own analytics and targeting content and advertisements on our Websites and elsewhere online, we may work with third-party network advertisers, ad agencies, analytics service providers, and other vendors to provide us with such information and services. These service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you. Some of these parties may collect personal information over time when you visit the Websites or other online websites and services. We may share Usage Data or de-identified data about visitors with third-party advertising companies, analytics providers and other vendors for analytics and advertising purposes.
PART 7: OPTING OUT OF BEHAVIORAL ADVERTISING
Lotame is a member of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and has implemented opt-out procedures in accordance with those organizations’ programs. Some of our advertising service providers may also be members and offer an opt-out of behavioral advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the opt-out offered by NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides an opt-out by participating companies in the DAA Self-Regulatory Program. If you would like to opt-out of behavioral advertising controlled by Lotame you may visit the NAI and DAA links provided above, or click here. Please note that Lotame and other companies may still collect information when you are online and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online.
PART 8: HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Lotame does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
PART 9: CONSUMER CHOICE
If you would like to update, delete, or revise any personal information you submitted to us through lotame.com or any of Lotame’s other corporate websites, please send your request to email@example.com.
PART 10: EUROPEAN ECONOMIC AREA (LEGAL BASIS FOR PROCESSING PERSONAL DATA, PRIVACY SHIELD, AND SUBJECT ACCESS REQUESTS)
General Data Protection Regulation (GDPR)
Lotame has certain responsibilities as both a data controller and a data processor under the European Union’s General Data Protection Regulation (“GDPR”). Lotame views itself as a data controller with respect to the data collected from Lotame’s corporate websites. We have taken steps to ensure that Lotame has updated its policies and procedures to address GDPR. For a brief overview of Lotame’s commitment to GDPR compliance, please click here.
Lotame’s commitment to the Privacy Shield Principles covers personal information about residents of all nations in the European Economic Area (EEA), which comprises the European Union (currently including the United Kingdom), Iceland, Liechtenstein, and Norway (collectively, “EEA residents”) as well as all residents of Switzerland.
To learn more about the Privacy Shield program, and to view Lotame’s certification, please visit https:/www.privacyshield.gov/list.
With respect to its participation in the Privacy Shield Principles, Lotame is subject to the jurisdiction and enforcement powers of the United States Federal Trade Commission.
Lotame may be liable in some circumstances for transferring personal information to a third party that violates the Privacy Shield Principles.
Upon the request of clients and partners, Lotame may also agree to be bound by the terms of the EU Standard Contractual Clauses.
In certain cases you may have the right to request binding arbitration of non-monetary claims that are not otherwise resolved by the procedures listed here (see https://www.privacyshield.gov/welcome, as described in the EU-US Privacy Shield Annex I and the Swiss-US Privacy Shield).
For information about how Lotame uses personal data obtained from its corporate websites, EEA residents should contact Lotame via email at: firstname.lastname@example.org or by mail at 8850 Stanford Blvd, Suite 4000, Columbia, MD 21045, Attention: Legal Department. Lotame has appointed its General Counsel and VP of Global Privacy as Lotame’s Data Protection Officer for GDPR purposes. EEA residents have the right to request certain information from Lotame, including without limitation, the right to ask what personal data Lotame has collected on you from the EEA and the right to ask that Lotame correct this personal data if you believe it to be inaccurate. You may submit a request using the following form.
The DPO will work with the broader Lotame team to respond to all inquiries within thirty (30) days of receipt. Lotame will respond in good faith to these inquiries but may not be able to provide complete information if your request requires Lotame to release confidential information of third parties, or otherwise imposes an undue burden or expense.
Lotame may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Lotame continues to voluntarily submit unresolved privacy complaints of EEA residents and Swiss residents to an independent dispute resolution mechanism administered by ANA. If you do not receive timely acknowledgment of your complaint, or if Lotame does not satisfactorily address your complaint, you can reach the ANA for more information and to file a complaint at:
Privacy Shield Line:
Attn: Privacy Shield
225 Reinekers Lane, Suite 325, Alexandria, VA 22314
In the event a satisfactory resolution cannot be resolved through the ANA, Lotame will cooperate with the United States Federal Trade Commission and any data protection authorities of the EEA member states and Switzerland to investigate and resolve any open complaints.
PART 11: YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS)
If you are a California resident, California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and California Civil Code section 1798.83, provides you with additional rights regarding our collection, disclosure and, if applicable, sale of your personal information. “Personal information” has the meaning given it in the CCPA.
Collection of Personal Information
Categories of Personal Information Collected (corresponds to categories listed in CCPA §1798.140(o)(1))
Lotame has collected the following categories of Personal Information in the preceding 12 months through its Websites:
|Category A: Identifiers||Unique personal identifier, online identifier, Internet Protocol address|
|Category F: Internet or other electronic network activity information||Interaction with our client’s or licensee’s web sites, applications, or advertisements|
|Category G: Geolocation data||Approximate physical location (derived from an Internet Protocol address)|
|Category I: Professional or employment-related information||Job title, employer name|
|Category K: Inferences||Consumer preferences, characteristics, behaviors|
Personal Information Sources
See Part 1: Information We Collect and How We Use It and Part 2: Tracking Technologies, listing the sources of Personal Information.
Purposes for Which Personal Information is Collected
See Part 1: Information We Collect and How We Use It, setting forth the purposes for which Lotame uses Personal Information.
Categories of Third Parties with whom Personal Information is Shared
See Part 3: Social Network and Platform Integration, and Third Party Links and Part 6: Third-Party Analytics Providers, Ad Servers, and Similar Third Parties, setting forth the categories of third parties with whom Lotame may share Personal Information.
Disclosure or Sale of Personal Information
Categories of Personal Information Disclosed or Sold (corresponds to categories listed in CCPA §1798.140(o)(1))
In the preceding 12 months, Lotame has disclosed the following categories of Personal Information for performing services on behalf of a client as their service provider and sold the following categories of Personal Information for conducting analytics or use in interest-based advertising or other marketing purposes for:
Category A: Identifiers
Category F: Internet or other electronic network activity information
Category G: Geolocation data
Category K: Inferences
Sale of Personal Information
Lotame does not sell any Personal Information that is collected through its Websites.
Your Consumer Rights Under the CCPA
Under CCPA, you may have the following consumer rights. Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA:
Right to Know
You have the right to request, at no charge, that we disclose to you the categories and specific pieces of Personal Information Lotame has collected about you in the prior 12 months, including:
You have the right to obtain the above information, in a portable and (if technically feasible) readily usable format.
Right of Deletion
You have the right to request the deletion of your Personal Information we have collected about you. This right may be subject to certain conditions and limitations under CCPA.
Right to Opt-Out of Sale
You have the right to opt-out of sale of your Personal Information we have collected about you.
Right to be Free from Discrimination
You may exercise all of the above rights at any time and Lotame will not unlawfully discriminate against you for exercising your rights under CCPA.
Submitting a Request to Exercise Your Rights
You may exercise any of your rights as set out above, by submitting a request as set forth below. You may be required to provide additional information to verify your identity and request before further action is taken. Please note that when submitting the following requests, Lotame is only able to apply your request to Personal Information that we use in our Data Products and Services, where we act as a business. For our clients where Lotame acts as a service provider, Lotame will inform our client of your request.
Exercising Your Right to Know, to Delete, and to Opt-Out of Sale
To exercise any of your rights as set out above, please contact us by:
You may be required to provide additional information to verify your identity and request before further action can be taken.
Appointing an Authorized Agent to Submit a Request on Your Behalf
You may use an authorized agent to submit a request to know or delete on your behalf. If you authorize an agent to make a request for you, the agent will be required to provide Lotame with written proof of your authorization and verification of your identity.
|Request Type||Received||Responded||Denied||Median Days to Respond|
|In Whole||In Part|
|Opt-Out of Sale|
To contact us with any questions, comments, or suggestions, please email us at email@example.com or write to us at Lotame Solutions, Inc., 8850 Stanford Blvd., Suite 4000, Columbia, Maryland, 21045, Attention: Legal Department.
PART 13: DATA SUBJECT ACCESS REQUEST FORM