Privacy Policy Old – Collective[i]

Introduction

This Privacy Policy (this “Policy”) applies to https://www.collectivei.com, https://intelligence.collectivei.com, https://intelligence.com and https://themodernsale.com (our “Website”) operated by Cross Commerce Media, Inc. d/b/a/ Collective[i] (“Company”, “we” or “us”).

We respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy (together with our Terms of Use and any other documents referenced therein or herein) describes the personal information that we may collect from you, or that you may provide on or through our Website, and how that information may be used or disclosed by us. This Policy also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

This Policy does not apply to information that we may collect through any other means, or to information collected on any other Company, affiliate, or third-party site, or by any third-party application that may link to or be accessible from our Website.

Please read the following carefully to understand our policies and practices regarding your personal information and how we may treat it. By using or accessing our Website, you agree to this Policy. This Policy may change from time to time and your continued use of our Website is deemed to be acceptance of such changes, so please check this Policy periodically for updates.

Information We May Collect About Our Website Users

We collect several types of information from and about users of our Website, including:

Information that you provide to us. This includes information, such as your name, email address and phone number(s), that you may provide by filling out any form on our Website, including in connection with subscribing to any service offered on our Website, posting any material on our Website, or requesting further information, products or services.
We may also ask you for information when you report a problem with our Website.
Information about your business, such as company name, company size, company location and business type, including business information that we may receive from third parties, such as LexisNexis.
Information that we may collect as you access or navigate through our Website, including usage details, IP addresses, and cookies and web beacons.
Records and copies of your correspondence with us (including emails) in the event you contact us.
Your responses to surveys that we might ask you to complete voluntarily for research purposes.

Information Collected Through Our Data Network Platform

We collect information under the direction of our clients, and have no direct relationship with the individuals whose personal data our clients process. Such information may include business information, such as company name, company size, company location and business type; business communications; and contact information, such as a person’s name, employer, job title, email address and phone number(s). Although we have no direct relationship with the individuals whose personal data our clients possess, we acknowledge that you have the right to access your personal information. An individual who seeks access to or who wants to correct, amend, or delete inaccurate data found on our platform and provided by one of our clients, should direct his or her query to our client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

We also collect information that individuals chose to contribute directly to our platform through intelligence.com. Such information may include business communications and contact information, such as a person’s name, employer, job title, email address and cell or phone number(s). Such individuals may request access to and may correct, amend, or delete inaccurate data found on our platform by emailing privacy@collectivei.com. If requested to remove data, we will respond within a reasonable timeframe.

We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our clients.

We will retain personal data we process on behalf of our clients for as long as needed to provide our services. We will retain this personal information as necessary to comply with our legal obligations, resolve disputes and/or enforce our agreements. For more information, see “Retention of Information Collected Through Our Data Network Platform” below.

Retention of Information Collected Through Our Data Network Platform

Some data you can delete whenever you like, some data we will delete upon request, some data is deleted by our application automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

Information retained until you remove it – such as your profile information, privacy settings, and account-related information. We will keep this data in your account until you choose to remove it and/or update it.
Information updated or deleted upon request – such as personally identifiable information that appears on our platform. We allow the “right to be forgotten”. To submit a request, please see “General Data Protection Regulation (GDPR) – European Representative” below or send an email to privacy@collectivei.com.
Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For instance, sales communications that are outdated and no longer useful for machine learning purposes can be deleted.
Information retained until your account is deleted – such as your username, password and log-in information. For security purposes, this information cannot be accessed after your account is deleted.
Information retained for extended time periods for limited purposes – sometimes business and legal requirements obligate us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment for you, we need to retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include: security, fraud and abuse prevention; financial record-keeping; complying with legal or regulatory requirements; and ensuring the continuity of our services.

Log Files, Cookies and Similar Technologies

As you navigate through our Website, for the purpose of system administration and in order to report aggregate information to our advertisers, we may also collect details of your visits to our Website, including, but not limited to, traffic data, location data, logs and other communication data, and the resources that you access, as well as information about your computer and internet connection, including your IP address, operating system and browser type.

We and our partners use cookies or similar technologies to:

Analyze trends;
Administer our Website;
Track users’ movements around our Website
Gather demographic information about our user base as a whole;
Estimate audience size and usage patterns;
Store information about a user’s preferences, allowing us to customize our Website according to such user’s individual interests;
Speed up user searches; and
Recognize users when they return to our Website.

Users can control the use of cookies at the individual browser level.

How We Use The Information Collected

We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

To provide you with our service in accordance with our clients’ or customers’ instructions, including any terms in our Subscription Agreement or our Terms of Use, as applicable.
To present our Website and its contents in a suitable and effective manner for you and for your computer.
To provide you with information about our products or services.
To notify you about changes to our products or services.
To allow you to participate in any interactive features that we may offer on our Website, when and if you choose to do so.

Disclosure of Your Information

We may disclose personal information that you provide via our Website to the following third parties: Instructions of Customers and Clients. We will disclose your personal information in accordance with a Client’s or Customer’s instructions, including any applicable terms in the Subscription Agreement and/or Terms of Use. Service Providers. We may disclose your personal information to contractors and service providers we use to support our business or our Website. These companies are authorized to use your personal information only as necessary to provide services to us, which may include but are not limited to payment processing, fulfilling subscription agreements and providing customer service.

Corporate Affiliates. We may disclose your personal information with our corporate affiliates, parents and/or subsidiaries. Mergers. We may disclose your personal information to a buyer in the event of a merger, divestiture, restructuring, reorganization, dissolution or any other form of sale of some or all of the Company’s stock or assets, whether as a going concern or as a part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about its customers is among the assets transferred. We may disclose your personal information in connection with a merger, divestiture, restructuring, reorganization, dissolution or any other form of sale, to any other third party without your prior written consent.

Legal Disclosure. We may disclose your personal information as required by law, such as to comply with any court order, legal process or other legal obligation, to enforce or apply our Subscription Agreement, Terms of Use and/or other agreements, to protect the rights, property or safety of the Company, our customers or others, which may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. With Consent. We may disclose your personal information with third parties when we have consent to do so.

Access and Choice About How We Use and Disclose Your Information

Upon written request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by emailing privacy@collectivei.com. We will respond to your request within a reasonable timeframe.

We strive to provide you with choices regarding the personal information you provide to us, and we have created mechanisms to provide you with the following control over your information:

Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Website may then be inaccessible or not function properly.
Newsletter(s). If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter(s) to you. You may choose to stop receiving our newsletter(s) or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or contacting us at privacy@collectivei.com
Advertisements. We partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on our Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking on this link https://preferences-mgr.truste.com (or if located in the European Union, by clicking on this link https://www.youronlinechoices.eu/. You may continue to receive generic ads.

You should review this Policy carefully. If you do not agree with our practices, your ultimate choice is not to use or access our Website. Remember, by using or accessing any part of our Website, you accept and agree to this Policy and our Terms of Use. If we update this Policy, your continued use of our Website (following the posting of the revised Policy) means that you accept and agree to the terms of the revised Policy.

User Contributions

You are responsible for any content, including personal information, that you may contribute to be published or displayed (hereinafter, “posted”) on our Website, or any portion thereof or page linked therein, or transmit to other users of our Website (collectively, “User Contributions”). Your User Contributions may be posted on and/or transmitted to other users of our Website, or others, at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Website with whom you may choose to share your User Contributions.
Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on our Website. You understand and acknowledge that, even after removal, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on our Website, including User Contributions, is governed by our Terms of Use and known or suspected violations should be reported to legal@collectivei.com.

Security

The security of your personal information is of the upmost importance to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@collectivei.com. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by using EDPO’s online request form or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium. UK General Data Protection Regulation (UK GDPR) – UK Representative

Pursuant to the UK GDPR, we have appointed EDPO UK Ltd (EDPO UK) as our UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by using EDPO UK’s online request form or writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

We (and our subsidiaries) participate in and have certified our compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (each, a “Privacy Shield Framework” or “Framework”). We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov. We are responsible for the processing of the personal data we receive, under each Privacy Shield Framework, and the subsequent transfer of such personal data to third parties acting as agents on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including in order to meet national security or law enforcement requirements.

If you have any unresolved privacy or data use concerns that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website (www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.” Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@collectivei.com. We will verify your request using the information associated with your account, including email address, if available. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We May Collect About Our Website Users section and the Information Collected Through Our Data Network Platform section above. We collect this information for the business and commercial purposes described in the How We Use The Information Collected section above. We share this information with the categories of third parties described in the Disclosure of Your Information section above.

Collective[i] does not put or sell (as such term is defined in the CCPA) your data on the open market. However, under the CCPA, “sale” is very broadly defined and some sharing of personal information necessary to provide our clients with accurate business contact information may be considered a “sale,” even if no money is exchanged. We want to make sure that California consumers have choices under this new definition of “sale.”

In the 12 months before the date of this Policy, a “sale” of the following categories of personal information under CCPA may have occurred:

Identifiers (such as name, business mailing address, email address, phone number and other business contact information);
Professional related information (specifically current and/or prior places of employment).

This information is shared with Collective[i] clients so that they can use the most accurate and up-to-date contact information for their business-to-business communications and is provided subject to license agreements that limit the information’s use to those purposes.

To opt out of the sale of your personal information, please complete our CCPA Opt Out Form (which can be found by going to the Privacy page at www.collectivei.com) or contact us at privacy@collectivei.com. We may ask for your permission to resume sale of your personal information at a later date, but we will wait at least 12 months before doing so.

Persons Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information on or through our Website. We do not knowingly collect personal information from anyone under 18. If you are under 18, please do not send any information about yourself to us, including your name, address, phone number(s) and email address. In the event that we learn that we have collected personal information from a person under the age of 18, we will delete that information. If you believe that we might have any information from or about a person under the age of 18, please contact us at legal@collectivei.com.

Changes to Our Privacy Policy

We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

To ask questions or send comments about this Policy and our privacy practices, you may email privacy@collectivei.com or send mail to:

Collective[i]
c/o Legal Department
450 Park Avenue South, 3rd Floor
New York, NY 10016

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