Last updated to address Privacy Shield and effective as of September 20, 2016.
Information We Collect and How We Use It
Lotame collects non-personally identifiable 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.
“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.
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.
Information Third Parties Provide About You
How and When We Disclose Information to Third Parties
- with our vendors and third-party service providers to perform certain services on behalf of the Websites, such as hosting the Websites or Websites’ features, sending email or other communications, and providing marketing assistance and data analysis;
- to comply with legal process or a subpoena, or at the request of a governmental entity conducting an investigation, and to protect and defend the legal rights or property of Lotame, our Websites or its users, or any other party; and
- in connection with a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of assets), including during the course of any due diligence process .
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.
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.
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 visit https://www.lotame.com/opt-out-preference-manager/. 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.
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.
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.
International Jurisdictions, Onward Transfer, and Privacy Shield
Lotame complies with the EU-U.S. Privacy Shield Framework Principles (the “Privacy Shield Principles”). Lotame has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to the collection, use and transfer of personal data from the European Economic Area to the U.S. When Lotame discloses personal data to third parties, after the transition period allowed by the Privacy Shield Framework, it will do so only when those third parties have provided contractual assurances that they are committed to processing personal data in accordance with the Privacy Shield Principles.
Lotame’s commitment to the EU-US Privacy Shield Framework 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”). The program also will be extended to personal information from Switzerland if and when that country adopts the necessary decision to do so.
To learn more about Privacy Shield, and to view Lotame’s certification, please visit http://www.privacyshield.gov/list.
With respect to its participation in the EU-U.S. Privacy Shield Framework, 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.
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 www.privacyshield.gov, Annex 1).
EEA residents have the right to request certain information from Lotame, including 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. 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 to an independent dispute resolution mechanism administered by DMA. If you do not receive timely acknowledgment of your complaint, or if Lotame does not satisfactorily address your complaint, you can reach the DMA for more information and to file a complaint at:
Privacy Shield Line
Direct Marketing Association
1615 L St, NW Suite 1100
Washington, DC 20036-5624
To file a complaint/inquiry: https://thedma.org/shield-complaint-form/
In the event a satisfactory resolution cannot be resolved through the DMA, Lotame will cooperate with the United States Federal Trade Commission and any data protection authorities of the EEA member states to investigate and resolve any open complaints.
California Residents – Your California Privacy Rights
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request by email to firstname.lastname@example.org write to us at: 8850 Stanford Blvd., Suite 4000, Columbia, MD 21045 Attn: Legal. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. Please note that we are only required to respond to one request per person each year.
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.