What is Personal Information or Personal Data?
This is information that identifies, or can be used on its own or with other information to identify, contact, or locate,  an individual “Personal Information” or “Personal Data”.

What Personal Information do we collect?
Examples of Personal information collected through our Site or Platform may include your name, e-mail address, company name, job title, contact details and company address.

How and When do we collect Personal Information?
You are free to explore our Site without providing any Personal Information about yourself. We collect information from you when you sign up for a Platform or when you elect to view/download our thought leadership content, respond to a survey, or fill out a form on our Site. When you provide Personal Information to us, we ask if you want to receive future marketing information and communication from us. You can absolutely choose to opt out of this communication. In the event you have previously enrolled in receiving communications, you can choose to opt out by emailing a request to privacy@mblm.com, or by clicking on the unsubscribe link in any email communication.

How do we use your Personal Information?
Information Collected through our Site: We may use the Personal Information we collect from you via our Site in the following ways:

  • To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To improve our Site in order to better serve our visitors.
  • To send periodic emails regarding our research, studies, and offerings.

Information Collected through our Platform: We use the Personal Information collected through our Platform from you for the following purposes:

  • To fulfill services that are fundamental to the platform (which may include the detection, prevention and resolution of security and technical issues);
  • To respond to user support requests; and
  • Otherwise to fulfill the objectives, deliverables, and obligations under each client agreement/contract.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details at the end of this Privacy Notice.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Data retention
We only store your Personal Information for as long as it is necessary to fulfill the above-mentioned purposes or until you object to the data processing. Thereafter, the data will be deleted or blocked if the deletion conflicts with statutory provisions or legitimate interests. A legitimate interest exists regarding the assertion, exercise or defense of legal claims.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so

Legal Basis for use of Personal Information
Site:
When we collect information about you through our Site, the legal basis on which we process your Personal Information is our legitimate interests, namely, to provide you with research and thought leadership information and the related marketing of our offerings.

Platform:
When we collect information about you through our Platform, the legal basis on which we process your Personal Information is the performance of a contractual agreement.

Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and

We use cookies to:

  • Understand and save user’s preferences for future visits.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features will be disabled. It won’t affect the user experience.

Website:
When you visit our Website, we will ask your permission to enable cookies.

Who we Share your Information With
MBLM does not sell, trade, or otherwise transfer to outside parties your Personal Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential and treat it in accordance with the law. Where any such parties process your Personal Information on our behalf, they are only permitted to do so in accordance with our instructions.  We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Google
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Site.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative opt-out page or permanently using the Google Analytics Opt-Out Browser add-on.

Rights for EEA Residents
If you are a resident of the EEA, the new European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their Personal Data. Accordingly, we have implemented additional transparency to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

  • Right of Access – the right to be informed of and request access to the Personal Data we process about you;
  • Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
  • Right to Erasure – the right to request that we delete your Personal Data;
  • Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your Personal Data;
  • Right to Object –
    • the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation;
    • the right to object to your Personal Data being processed for direct marketing purposes;
  • Right to Data Portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service; and
  • Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
  • Obligation to provide Personal Information- you do not need to provide Personal Information to use our Site. For use of our Platform your name, email and Company name may be required in order to use the software.

As an affected person, you have the right to lodge a complaint with a supervisory authority. The supervisory authority that files the complaint will notify you of the status and outcome of your complaint, including the possibility of a judicial remedy.

Please email us at privacy@mblm.com for assistance with any of the above items.

California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our homepage or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found on the page specified above. Users will be notified of any privacy policy changes on our Privacy Policy Page
Users are able to change their Personal Information by emailing us at privacy@mblm.com

How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
Our Site and Platform is not intended for use by children and we do not knowingly collect data relating to children. When it comes to the collection of Personal Information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. If you believe that we might have any information from a child, please contact us at support @mblm.com.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect Personal Information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email within 7 business days
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

Send information, respond to inquiries, and/or other requests or questions.

To be in accordance with CANSPAM we agree to the following:

  • NOT use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can click here.

Follow the instructions at the bottom of each email. And we will promptly remove you from ALL correspondence.

Transfers of Your Personal Data to Other Countries
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and process your Personal Data in the United States and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries by using appropriate safeguards. By using our Site and/or Platform, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Platform are appropriate or available in any particular jurisdiction.

If you would like more information regarding the specific mechanism used by us when transferring your Personal Data outside of the EEA, please email us at privacy@mblm.com.

Changes to this Privacy Policy
We may occasionally make changes to this Privacy Policy.
When we make material changes to this Privacy Policy, we’ll provide you with notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Site, Platform or by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.

Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below.

MBLM
Attn: Amy Clausi
114 W 27 St, 2nd Floor
New York, NY 10001
USA
privacy@mblm.com
+1 212 979 8200