PRIVACY POLICY

Last Update: October 26, 2023

Malvern Media, Inc. provides its clients with consumer information including Personal Information for data management, distribution, analytics and their marketing services.  Through analysis of the data we provide our clients are able to provide more relevant marketing, determine security risks, and have a better understanding of what type or style of marketing appeals to their customers or customer basis they seek to attract.  We do not directly collect the consumer information, but rather we receive it from third parties who have collected the information and placed it with us.  This Privacy Policy describes our collection and use consumer information, including Personal Information from this Website as well as  that which we receive from our Clients.  We do not collect or accept information from or about children under the age of sixteen and if accidentally collected, it is deleted upon discovery. We may change or update this Privacy Policy upon posting here with no further notice to you.

1. INFORMATION WE COLLECT AND HOW WE COLLECT INFORAMATION.

Information Collected From Third-Party Sources. We receive data from a variety of consumer-facing companies who have collected the data from their websites, applications, products and services.  We may also receive data from other data compilers and suppliers. We also may obtain data through public records or sources. Parts of the data we receive includes Personal Information or is linked to Personal Information including:

  • Identifiers, which includes your name, physical address, email address, phone number, mobile number, and identity information relating to data used to identify an individual.

  • Characteristics of protected classifications under applicable laws, such as your age and date of birth.

  • Commercial information, such as profile information relating to your interests, feedback information, communication preferences, social media activities, or your actions online when opening or clicking through your email. It may also include a history or tendencies toward products you have purchased in the past or are seeking to purchase.

  • Internet or other electronic network activity information, which includes your IP address, log data, analytics data, device ID, and other data collected through cookies, web beacons, JavaScript, and similar technologies. From this information we may have collected your browsing history, search history, interaction with a website, application, or advertisement.

  • Geolocation data, which includes your general geographic location and may include your precise address.

  • Inferences drawn from other Personal Information or data, using your Personal Information we or our clients may draw an inference about interests and preferences you may have  in products, services or other information based on a third-party’s analysis. From information provided by third-parties, we or our clients may be able to create a profile a general understanding of your preferences, characteristics, and personal preferences to determine what ads or products or services you may be interested in receiving.

Information Automatically Collected by Clients and Provided to Us. When you visit or interact with websites or emails, our clients may use a variety of technologies such as cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies or third-party services to automatically or passively collect Personal Information about you and your interactions with websites of our clients and they may provide this to us. This includes:

·          Computer or Device Information: Your Internet Protocol ("IP") address or other unique identifier or information from the computer, mobile device, or tablet you use to access the websites, including but not limited to, your browser type, device type, system type, and the domain name from which you accessed the websites are collected by our clients.

·          Usage Information: In addition, information is collected about your use of email promotions, including the date and time you opened, and if you visited the website that was the subject of an ad, as well the page or app you visit after leaving our services, the amount of time you spend viewing or using the websites, the number of times you return to the websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the websites. For legal compliance purposes, we may also capture or record your interactions with the website to confirm that your information was submitted through us.

·          Third-party collectors:  As described above we receive the majority of data in our database from third party clients of ours who place the information they have collected with us for a variety of reasons including targeted marketing, product and service development by third parties.

·          Service Providers: We or our Clients may use third-party service providers to support our services, or they may also provide us information for our use. Some service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.

Combining Information. We may combine the Personal Information we receive from you, third-parties, and information we automatically collect through the Websites and/or Services, as well as information collected from other online or offline sources, including from third-party sources. This will provide us with a profile of you which we may be able to use for provision of our Services to you as well as identify other products and services that may interest you.

Information Collection and Use on Our Website. Our Website is our primary advertising to businesses that may wish to use our services. When Our Website is visited or when we are engaging by email, we may collect and use the following information for the following uses:

·         Personal Information. When you provide us with information through our website or by email, we collect any information you provide to us including Personal Information.  We your Personal Information for the business purpose for which you are contacting us, including opening and administration of your account and provision of services, and general communications.  We may on occasion communicate with you regarding changes to services, to respond to your inquiries, and send marketing and services updates. We may also use it to analyze how customers are using our website or services.

·         Non-Personal Information. We collect other information when you visit our website. This includes information we collect using cookies, web beacons, and similar technologies, and may target or retarget ads to you using those cookies, device identifiers, or similar technologies, when you browse the Internet or use your mobile device. We use this information to promote our business, provide security to our databases, and undertake analytics.  We may combine any information including PI you provide to us.  This Information May Include:

·            The type of browser and operating system you have used to access the website,

·            a time-stamp, and other browser or device information;  

·            Your IP address providing general geographic location;

·            Your clickstream data and any URL referral information ;

·            What part(s) of our website you visit and view, and how long you view it;

·            A unique identifier, which we may associate with a cookie, device identifier or similar technology.

·         Cookies, Web Pixels, and Similar Technologies.  This section provides more information about cookies and similar technologies that we and our clients may use, and how they work.

·         Cookies. Cookies are small text files that websites and other online services use to store information about users on users’ own computers. For instance, cookies can be used to store sign-in credentials so that you do not have to enter them each time you return to a website, or to store other information to make web viewing more customized or efficient upon future visits. Cookies also may store a unique identifier tied to your computer so that web services and content and advertising networks can recognize you across visits to different websites. You can configure your internet browser to warn you each time a cookie is being sent or to refuse all or certain cookies completely. However, this may interfere with the functionality of your web browsing or your ability to fully use websites.

·         Pixels and Web Beacons. Pixels and web beacons may also collect and sent information from your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Web beacon, the IP address of your computer, and the URL of the web page from which the Web beacon was viewed.

·         Client Use of Technology. Please note that our clients use cookies and pixels, which we have no control over. However, we do provide clients data lists that de-identify Personal Information and any other information we have provided and instead associate them with online cookies or similar technologies. Some of our clients may also associate cookie or pixel information with device identifiers  in order to associate use identities across browsers, devices, or technologies.  Our clients may also combine information or data we have provided with information they have collected through their own use of Technology.

2. WHO WE DISCLOSE, SHARE, AND SELL YOUR PERSONAL INFORMATION TO.

We may disclose, share, and sell your Personal Information as described below.

·         Third-party Product and Service Providers. We may share any type of data, including PI with agents, business clients and service providers  We provide data to these parties to help send or target advertising by or on behalf of our clients, for analytical purposes, to measure campaigns, or design future campaigns. We may  do so to facilitate the sending of display media, email, or other requested services. They may also link consumer information, enhance identity and social graphs, activate users, and create look-alike audiences in order to target consumers better.

·         Clients. Our clients use the database we provide to them for data onboarding, online and offline linkage, direct marketing, customer acquisition, appending, look-alike modeling, DMP/DSP usage, data analytics, individual vs. household confidence level matching, site personalization and building robust consumer profiles.  They may also use it for postal or email marketing targeting consumers with specific categories of ads, services and products.

·         Parent and Affiliated Companies. We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.

·         Service Providers. We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.

·         Sale or Transfer of Business or Assets. If another entity acquires us or any of our assets, information we have collected may be transferred to such entity. If we file for bankruptcy or reorganization, information about you may be considered our asset and may be included in the assets transferred.

·         Marketing Vendors, Service Providers, and Other Third-parties. We may disclose, share, or sell Personal Information to third-parties who provide display and/or email services or other third-party vendors who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for third-parties use on and to manage and improve advertising campaigns.

·         Compliance with Laws. We may disclose Personal Information to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclose and share Personal Information to third-parties to assist us in compliance with Laws.  

·         Enforcing Our Rights. We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes, with clients, third-party service provides and other third-parties or contractors who provide you with the product or service which you have requested or to protect the security of our Websites, servers, network systems, and databases and enforce our contractual rights with these parties.

·         Aggregate or Anonymous Non-Personal Information. We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.

3. YOUR CHOICES AND OPTING OUT.

Cookies and Tracking Technology. You may decline or adjust these technologies through your device or Internet browser settings to limit certain tracking or to decline cookies. Please note that by doing so, you may not be able to use certain features on our Websites or take full advantage of all of our offerings. Please refer to your device's settings or your Internet browser's "Help" section for more information on how to delete and/or disable cookies or to control your tracking preferences. Please note that websites may not recognize "do not track" requests or headers from all browsers.

Unsubscribing from Our Marketing Communications. To remove your information from our marketing databases, you may simply click the opt-out link in each email. If you receive marketing communications from one or more of our affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.

Third-Party Communications. Any third-parties to whom we have disclosed, shared, or sold your information may have their own privacy policies which describe how they use and disclose your information and your choices. We encourage you to visit the websites of those third-parties.

4. DATA SECURITY.

We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of information, communications, and data to us or through our Website is at your own risk.

5. CHANGES TO OUR PRIVACY POLICY.

We reserve the right to make changes to this Privacy Policy including collection, use, sale and sharing of your Personal Information. We do not provide notice of changes except through our posting on this page. We use your information only in the manner described in this Privacy Policy at the time you register your information with us. Please be sure to review this policy each time you communicate or register with us for the latest policy. Your continued use of the Websites and/or Services after we post a change in the Privacy Policy means you accept those changes.

6. CALIFORNIA RESIDENT RIGHTS.

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of Personal Information (as defined in the Shine the Light law) to third-parties for their direct marketing purposes.

California Consumer Privacy Act of 2018. This Privacy Notice for California Residents supplements the information contained in our primary privacy policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

Additional Personal Information Disclosures.

·         Additional Disclosures on Sales, Sharing, or Targeted Advertising. As further described in the Privacy Policy, we may “sell” or “share” your Personal Information (as those terms are defined by the CCPA to third-parties, subject to your right to opt-out of those sales.

In the last 24 months, we sold, shared (for cross-context behavioral or targeted advertising purposes), or disclosed the Personal Information (for the purposes described in our Privacy Policy) as follows:

·         Third-party Business (clients) and Marketing Companies: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.

·         Online Advertising Networks, Social Networks, and Analytics Providers: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.

·         We also disclose Personal Information to third-parties at your direction or upon your request, in connection with a service or product you have requested or received; for our corporate business transaction; or to comply with legal or contractual obligations; as described in our Privacy Policy. In the last 12 months, we may have disclosed each category of Personal Information for these purposes.

·         Sensitive Personal Information. We may receive, collect, share, and sell your resident or business address in order to provide services.  Except for your address, we do not collect, share, or sell any other Sensitive Persona Information. We have collected general geolocation for targeted advertising and marketing, or for cross-context behavioral or targeted advertising.

·         De-identified Information. We may receive or process Personal Information to create, de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law.

California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

·         RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:

·         The categories of Personal Information collected;

·         The categories of sources of the Personal Information;

·         The purposes for which we collected the Personal Information;

·         The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;

·         The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and

·         The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.

·         RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.

·         RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.

·         RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. The right to exercise control over our collection and processing of Sensitive Personal Information.

·         RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION. The right to direct us not to “sell” your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share, and sell your Personal Information to the third-parties who provide to you the services and products you requested at registration.

·         RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

·         RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.

How to Exercise Your Rights. Submit your request to exercise one of the privacy rights identified above, as follows:

 

Use our Privacy Portal: https://privacyportal.privacypillar.com/dsar/form?orgid=369c8ff9-8ffb-4308-8362-f01691e77db8&propid=64c8904f-8bac-4dd9-8e6c-d052be1918a2&formid=6e6ff4b8-2296-4589-ae7f-563fa743ec2d&status=publish

Use our Toll-Free Telephone Number: 1-800-702-3830

Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code. We may at times need to request additional Personal Information from you, taking into consideration our relationship with you and the sensitivity of your request.

We will process requests to opt-out of sales within ten (10) business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within forty-five (45) days, subject to any applicable exceptions and extensions permitted by law.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.

Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Retention of Personal Information. We retain Personal Information as long as is necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision.  We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. In addition, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the Services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.