Effective May 25, 2018.
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 email@example.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:
Information Collected through our Platform: We use the Personal Information collected through our Platform from you for the following purposes:
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.
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
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.
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’?
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.
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.
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.
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:
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 firstname.lastname@example.org for assistance with any of the above items.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Users are able to change their Personal Information by emailing us at email@example.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:
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
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 firstname.lastname@example.org.
Please, therefore, make sure you read any such notice carefully.
Attn: Amy Clausi
114 W 27 St, 2nd Floor
New York, NY 10001
+1 212 979 8200