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Privacy Notice

Effective Date: July 23, 2024

Introduction and Overview

This Privacy Policy provides a comprehensive description of how Next Millennium Media Inc. (“Next Millennium” “we” “our” or “us”) collects, uses, and discloses information about you, as well as your rights and choices regarding such information. It applies to any personal data that we process.

To the extent permitted by law, by using our internet advertising exchange system (the “Service”) or interacting with us via another means, you consent to our collection, use, and disclosure practices and other activities as described in this Privacy Notice.

If you are a Nevada, California, Virginia, Colorado, Connecticut, or Utah resident, please see the “Additional Disclosures” section below that applies to your state. If you are a resident of Canada, please see the “Additional Disclosure for Canada Residents” section below. If you are a Data Subject in the European Union or the United Kingdom, please see the “Additional Disclosures for Data Subjects in the European Union or United Kingdom” section below. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.

Information Collection

Information We Collect Directly from Our Customers or Other Business Relations

We collect information for our own use about you when you use the Service or interact with us offline, including information you provide when you register an account, update your profile, access our content, make a purchase, or contact us. This data does not include any cookie data or other data collected automatically from users of our customers’ websites.

The following are the categories of information we collect directly and have collected directly in the last 12 months:

  • Contact Data including your first and last name, email address, postal address, and phone number.
  • Profile Data including your interests, inferences, preferences, and favorites.
  • Content including content within any messages you send to us (such as feedback and questions to customer support).
  • Billing Data including your payment instrument number and billing address to process your payments.

Information Collected Automatically from End Users’ Devices

We automatically collect information when individuals use the Service by visiting a customer website. To do this, we may, among other methods, use various tracking technologies to automatically collect information when you use our customers’ websites, including the following:

  • Log Files: Which are files that record events that occur in connection with your use of the Service.
  • Cookies: Which are small data files stored on your device that act as a unique tag to identify your browser. These files can record information about your internet usage that occurs in connection with your use of the Service.
  • Pixels (also known as web beacons): Which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may send us information. Pixels are used along with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising via the Service, and provide you with additional functionality such as the ability to connect our Service with your social media account.

The categories of information we automatically collect for our own use in the last 12 months includes:

  • Service Use Data including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
  • Device Data including data about the type of device or browser you use, cookie id, your device’s operating software, your internet service provider, and your device’s regional and language settings.
  • IP Address which we use to determine imprecise location data (such as data that indicates a city or postal code level).

We also provide products and services for our customers which includes processing information about individual end users to be used for automated decision making and providing targeted advertising to end users at the direction of our customers on their behalf (“Customer Data”).

Customer Data includes demographic data, content, service use data, website browsing data, device data, device connectivity configuration data, and IP Address, among other information.

Our processing of Customer Data is governed by the terms of our service agreements with our customers and not this Privacy Policy.

We are not responsible for how our customers treat the information we process on their behalf, and we recommend you review their privacy notices and cookie policies.

For further information on your rights and choices regarding Customer Data, see the “Your Rights and Choices” section below.

Purposes of Processing the Information Collected for Our Own Use

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Notice. Our business purposes for processing the information we collect include aiding us in:

  • Operating and managing the Service, including our “Contact Us” feature on the Service.
  • Performing services requested by you, such as responding to your comments, questions, and requests, and provide customer service.
  • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Monitoring and analyzing trends, usage, and activities on websites you visit.
  • Conducting research, including focus groups and surveys.
  • Improving the Service.
  • Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been de-identified) for any purpose except as prohibited by applicable law.

Disclosure of Information

The circumstances and types of entities to whom we disclosed information in the last 12 months include the following:

  • Service Providers: We disclose the data we collect for our own purposes to entities that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, website hosting, and technical support. We may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Customers: We disclose “Customer Data” to our customers in connection with us processing information on their behalf. For example, we disclose information with our customers in order to facilitate orders, respond to questions and comments, comply with requests, and otherwise comply with applicable law.
  • Merger or Acquisition: We may disclose information in connection with or during negotiations of any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure: We disclose information to comply with the law or other legal process and where required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security, and safety of us, the Service, or anyone else.
  • Facilitating Requests: We disclose information at your request or direction.
  • Consent: We disclose information with our customers or service providers with notice to you and your consent.

Notwithstanding the above, we may disclose information that does not identify you (including information that has been de-identified) except as prohibited by applicable law.

Social Media and Technology Integrations

We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. For example, our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.

Please note that when you interact with other entities, those entities may independently collect information about you and solicit information from you. Such information collected and stored by those entities remains subject to their own policies and practices, including what information they disclose to us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Privacy Choices You Can Make

Tracking Technology Choices

Cookies and Pixels: Most browsers accept cookies by default. You can instruct your browser by changing its settings to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you as a user disable or remove tracking technologies, some websites or applications may not function correctly.

Analytics and Interest-Based Advertising

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of or compliance with any opt out options or programs or the accuracy of any other entities’ statements regarding their opt out options or programs.

Communications

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails such as those about your account, transactions, servicing, or Next Millennium’s ongoing business relations.

Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.

Children

The Service is intended for a general audience and is not directed at children under (13) years of age. By providing us with your data, you warrant to us that you are over 13 years of age.

We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at Privacy@nextmillennium.io. We will remove the data to the extent required by applicable laws.

We do not knowingly “sell” as that term is defined under the CCPA the personal information of minors under 16 years old who are California residents.

Data Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure, and we cannot guarantee the security of information about you.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature, and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means, and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for a period of time after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

International Transfer

We are based in the U.S. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence.

Changes to this Privacy Policy

We reserve the right to revise and reissue this Privacy Notice at any time. Any changes will be effective immediately upon posting of the revised Privacy Notice. Your continued use of our Service indicates your consent to the Privacy Notice then posted. If the changes are material, we may provide you additional notice to your email address.

Contact Us

If you have any questions or comments about this Privacy Notice, our data practices, or our compliance with applicable law, please contact us:

By email: Privacy@nextmillennium.io

By mail: One World Trade Center, Suite 8506, New York, NY 10007

This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at Info@nextmillennium.io.

Additional Disclosures for Nevada Residents

Nevada law grants you the right:

  • To review and request changes to any covered information that we collect.
  • To request that we not make any sale of any covered information we have collected or will collect about you.

If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at Privacy@nextmillennium.io.

Additional Disclosures for California Residents

Rights

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides the following rights:

  • The Right to be Informed: You have the right to be informed of the categories of personal information we collect and the purposes for which the categories of personal information are collected or used and whether that information is sold or shared.
  • You have a right to be informed of the categories of sensitive personal information we collect and the purposes for which the categories of sensitive personal information are collected or used and whether that information is sold or shared.
  • You have a right to be informed of the length of time we intend to retain each category of personal information, including sensitive personal information, or if that is not possible, the criteria used to determine that period.
  • The Right to Delete Personal Information: You have the right to request that we delete any personal information about you which we have collected from you. If it is reasonably necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
  • The Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate personal information.
  • The Right to Know What Personal Information is Collected and to Access that Information: You have the right to request that we disclose to you the following:
    • The categories of personal information we have collected about you.
    • The categories of sources from which the personal information is collected.
    • The business or commercial purpose for collecting, selling, or sharing personal information.
    • The categories of third parties to whom we disclose personal information.
    • The specific pieces of personal information we have collected about you.
  • The Right to Know What Personal Information is Sold or Shared and to Whom: You have the right to know the following:
    • The categories of personal information that we collected about you.
    • The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared.
    • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
  • The Right to Opt Out of Sale or Sharing of Personal Information: You have the right at any time to direct us not to sell or share your personal information. This right may be referred to as the right to opt-out of sale or sharing.
  • You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by calling our toll-free number at 212-727-0006 or emailing us at Privacy@nextmillennium.io.
  • The Right to Limit Use and Disclosure of Sensitive Personal Information: Next Millennium Media does not collect or process sensitive personal information for the purpose of inferring characteristics about a consumer.
  • The Right of No Retaliation: You have the right not to be discriminated against because you exercised any of the above rights.

You can exercise any of your rights by filling out a consumer rights request form HERE, calling us toll free at 212-727-0006, or emailing us at Privacy@nextmillennium.io.

Notice of Collection

In the past 12 months, we have collected the following categories of personal information:

  • Identifiers including name, email address, postal address, phone number, cookie id, Internet Protocol (IP) address, Profile Data, Billing Data, user ids and account name, demographic data, content, Service Use Data, Device Data, device connectivity configuration data.
  • Internet activity including interactions with a website, email, or advertisement.

For more information on information we collect, including the sources we receive information from, review the Information Collection section. We collect and use these categories of personal information for the business purposes described in the Purposes of Processing the Information Collected for Our Own Use section, including to provide and manage our Services.

Selling and Sharing Your Personal Information

Next Millennium does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA/CPRA is interpreted to include our advertising technology activities as a “sale,” we will seek to comply with applicable law as to such activity.

Next Millennium shares or sells the following categories of personal information for the purposes of providing targeted advertising:

  • Internet Protocol (IP) address, demographic data, content, Service Use Data, Device Data, device connectivity configuration data.
  • Internet activity including interactions with a website, email, or advertisement.

Other Disclosures

Next Millennium discloses the following information about consumers for other business purposes:

  • Contact Data including your first and last name, email address, postal address, and phone number.
  • Profile Data including your interests, inferences, preferences, and favorites.
  • Content including content within any messages you send to us (such as feedback and questions to customer support).
  • Billing Data including your payment instrument number and billing address to process your payments.
  • Service Use Data including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
  • Device Data including data about the type of device or browser you use, your device’s operating software, cookie id, your internet service provider, and your device’s regional and language settings.
  • IP Address which we use to determine imprecise location data (such as data that indicates a city or postal code level).
  • Location Data including imprecise location data (such as data that indicates a city or postal code level).

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Shine the Light

Residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) the names and addresses of all of the third parties that received personal information from the business for the third parties’ direct marketing purposes during the preceding calendar year and, if the nature of the third parties’ business cannot reasonably be determined from the third parties’ name, examples of the products or services marketed, if known to the business, sufficient to give the customer a reasonable indication of the nature of the third parties’ business. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Additional Disclosures for Virginia Residents

Rights

These additional disclosures for Virginia residents apply only to individuals who reside in Virginia. The Virginia Consumer Data Protection Act (“VCDPA”) provides the following rights:

  • You have a right to confirm whether or not we, as a controller, are processing your personal data and to access such personal data.
  • You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data.
  • You have the right to delete personal data provided by you or that we obtained about you.
  • You have a right to obtain a copy of your personal data that you previously provided to us as a controller in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another data controller without hindrance where the processing is carried out by automated means.
  • You have a right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We will not discriminate against you for exercising any of your consumer rights. You can exercise any of your rights by filling out a consumer rights request form HERE, calling us toll free at 212-727-0006, or emailing us at Privacy@nextmillennium.io.

You may appeal any decision by us regarding your rights by calling us toll free at 212-727-0006 or emailing us at Privacy@nextmillennium.io and indicating that you wish to appeal our decision.

Additional Disclosures for Colorado Residents

Rights

These additional disclosures for Colorado residents apply only to individuals who reside in Colorado. The Colorado Privacy Act (“CPA”) provides the following rights:

  • You have a right to opt out of the processing of personal data concerning you for the purposes of (1) targeted advertising, (2) the sale of personal data, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • We, as processors, do assist our customers in processing your data for the purposes of targeted advertising and the sale of personal data.
  • You have the right to confirm whether we are processing your personal data and to have access to that data.
  • You have the right to obtain information from us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • You have the right to correct inaccuracies in your personal data.
  • You have the right to delete personal data concerning you.

We will not discriminate against you for exercising any of your consumer rights. You can exercise any of your rights by filling out a consumer rights request form HERE, calling us toll free at 212-727-0006, or emailing us at Privacy@nextmillennium.io.

You may appeal any decision by us regarding your rights by calling us toll free at 212-727-0006 or emailing us at Privacy@nextmillennium.io and indicating that you wish to appeal our decision.

Additional Disclosures for Connecticut Residents

Rights

These additional disclosures for Connecticut residents apply only to individuals who reside in Connecticut. The Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) provides the following rights:

  • You have a right to opt out of the processing of personal data concerning you for the purposes of (1) targeted advertising, (2) the sale of personal data, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • We, as processors, do assist our customers in processing your data for the purposes of targeted advertising and the sale of personal data.
  • You have the right to confirm whether we are processing your personal data and to have access to that data, unless such confirmation or access would require us to reveal a trade secret.
  • You have the right to obtain information from us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • You have the right to correct inaccuracies in your personal data.
  • You have the right to delete personal data concerning you.

We will not discriminate against you for exercising any of your consumer rights. You can exercise any of your rights by filling out a consumer rights request form HERE, calling us toll free at 212-727-0006, or emailing us at Privacy@nextmillennium.io.

You may appeal any decision by us regarding your rights by calling us toll free at 212-727-0006 or emailing us at Privacy@nextmillennium.io and indicating that you wish to appeal our decision.

Additional Disclosures for Utah Residents

Rights

These additional disclosures for Utah residents apply only to individuals who reside in Utah. The Utah Consumer Privacy Act (“UCPA”) provides the following rights:

  • You have a right to opt out of the processing of personal data concerning you for the purposes of (1) targeted advertising, (2) the sale of personal data, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • We, as processors, do assist our customers in processing your data for the purposes of targeted advertising and the sale of personal data.
  • You have the right to confirm whether we are processing your personal data and to have access to that data, unless such confirmation or access would require us to reveal a trade secret.
  • You have the right to obtain information, to the extent it is reasonably feasible, in a portable and, to the extent practicable, readily usable format that allows you to transmit the data to another entity without hindrance.
  • You have the right to delete personal data concerning you.

We will not discriminate against you for exercising any of your consumer rights. You can exercise any of your rights by filling out a consumer rights request form HERE, calling us toll free at 212-727-0006, or emailing us at Privacy@nextmillennium.io.

Additional Disclosures for Canada Residents

The individual who is accountable for the organization’s policies and practices and to whom complaints or inquiries can be forwarded is:

Joe Gutman, Chief of Staff
Privacy@nextmillennium.io
One World Trade Center, Suite 8506, New York, NY 10007

You have a right, subject to certain exceptions, to access the information about you that we use and disclose.

You have a right to challenge the accuracy and completeness of your personal information and have it amended if appropriate.

Additional Disclosures for Data Subjects in the European Union and United Kingdom

Roles

Data protection laws in the European Union and UK distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

Next Millennium acts as a controller with our customers with respect to personal data we process for ourselves that is collected as you interact with our customers’ websites or our emails. With data we pass on to customers for their processing purposes, we are a data processor. Please visit the applicable customer’s privacy policy for information about their privacy practices.

Data Protection Officer (DPO)

We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Joe Gutman, Chief of Staff
Next Millennium Media Inc.
Privacy@nextmillennium.io
One World Trade Center, Suite 8506, New York, NY 10007

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by contacting our DPO at the email address above.

Lawful Basis for Processing

Personal data means any information capable of identifying an individual. It does not include anonymized data. The personal data that we collect about you is detailed in the “Information Collection” section above.

The detailed purposes of our information collection for our own use are located above in the “Purposes of Processing the Information Collected for Our Own Use” section.

Data protection laws in the Europe Union and the UK require a “lawful basis” for processing personal data. The lawful basis for each category of personal data we collect is as follows:

  • Contact Data including your first and last name, email address, postal address, and phone number. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue, or defend legal claims.
  • Profile Data including your interests, inferences, preferences, and favorites. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.
  • Content including content within any messages you send to us (such as feedback and questions to customer support). Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue, or defend legal claims.
  • Billing Data including your payment instrument number and billing address to process your payments. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • Service Use Data including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages. Our lawful ground for this processing is our legitimate interests.
  • Device Data including data about the type of device or browser you use, your device’s operating software, cookie id, your internet service provider, and your device’s regional and language settings. Our lawful ground for this processing is our legitimate interests.
  • IP Address which we use to determine imprecise location data (such as data that indicates a city or postal code level). Our lawful ground for this processing is our legitimate interests.
  • Location Data including imprecise location data (such as data that indicates a city or postal code level). Our lawful ground for this processing is our legitimate interests.

Customer Data is processed on behalf of our customers to provide you with targeted advertising. Customer Data includes demographic data, content, service use data, website browsing data, device data, device connectivity configuration data, and IP Address, among other information. Our Customers are responsible for gaining your consent for us to process this data.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Where we are required to collect personal data by law or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at the time.

Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). You can ask to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at Privacy@nextmillennium.io at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions such as purchases, warranty registrations, etc.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Disclosures

The parties to whom we disclose your information are specified in the “Disclosure of Information” section above.

International Transfers

We are based in the United States. However, we are subject to the provisions of the General Data Protection Regulations of the EU and UK that protect your personal data.

Your Data Subject Rights

Under the data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data, and (where the lawful ground of processing is consent) to withdraw consent.

UK Data Subjects can read more about these rights here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You may exercise your rights by submitting a written request to us at the email address set out in the “Contact Us” section above or using the data subject request form HERE. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If your personal data has been processed by us on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

Complaints

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator and would welcome you directing an inquiry first to us.

Third Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or disclose data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.