At Ai Media Group, LLC (referred to as “Company,” “us” or “we”), we recognize that your customer’s privacy is important. This Policy discloses the Company’s privacy practices, in connection with all products and services we may offer to you (collectively referred to as the “Services”). This Policy also covers how personal and other information that we receive or collect about your customers is treated. Please read the information below to learn the following regarding your use of our Services.
We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, and/or by placing a prominent notice on our web site. Your continued use of our Services after such modifications
will constitute your: (a) acknowledgment of the modified Policy; and (b) your agreement to abide and be bound by that Policy. If you have any questions about this Policy, or if you or your customers require more specifics as to what information the Company collects, where the information is sourced from, or whether it is being disclosed or sold and to whom, please feel free to contact us at: privacy@aimediagroup.com.
- Types of Information We Collect
In order to provide you with the Services, we collect two types of information about your customers: Personally Identifiable Information (“PII”) and Aggregate Information. Personally Identifiable Information: This refers to information that lets us know the specifics of who your
customers are. When your customers engage in certain activities, such as clicking on an advertisement or calling a phone number on the site, etc. we may collect PII about your customers. Examples of PII may include your customers’ first and last name and or company name, email address, mailing address (including zip code), employer, job title and department, telephone and facsimile numbers and other
identifying information. Aggregate Information: This refers to information that does not by itself identify a specific individual. We gather certain information about your customers when they click on advertisements. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This information may include the Website’s Uniform Resource Locator (“URL”) that points to the site your customer just
came from, which URL your customer goes to after clicking on an advertisement, what browser your customer is using, and your customer’s Internet Protocol (“IP”) address. - How We Collect and Use Information
We do not collect any PII about Your Customers unless they click on an advertisement or call a phone number listed on a website or advertisement created through the use of our Services, or otherwise through the use of our Services. In some cases, PII may be collected during a phone call initiated by Your Customers (by calling a phone number listed on a website or advertisement created through the use of our Services) and that phone call is monitored and recorded if You have requested such call monitoring and recording Services from Us.
We will primarily use your customer’s PII to track the amount of times your advertisement is accessed or to track the activity of your customer in connection with their viewing of an advertisement. We will also use certain forms of PII to improve your marketing and promotional efforts or to statistically analyze usage. We may use PII to deliver information to you and to contact you regarding administrative notices. Finally, we may use your PII to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Service contract and this Privacy Policy. We may also collect certain Aggregate Information. For example, we may use your customer’s IP address to diagnose problems with servers or software and to gather demographic information. Our third party advertising partners may also provide us with aggregate, but not individual, reports that will tell us how many ads were presented and clicked upon. - Cookies
2130262549 v4 ©2019 Ai Media Group, LLC We may store cookies on your customers’ computer in order to collect certain aggregate data about your customers. A cookie is a small data text file which is stored on your customers’ computer that uniquely identifies your customers’ browser. Cookies may also include more personalized information, such as your customer’s IP address, browser type, the server your customer’s computer is logged onto, and the area code and zip code associated with
your customer’s computer. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing account and advertising preferences that have been set, and personalizing the Services we make available to your customer. - Release of Information
We will not sell, trade, or rent your customer’s PII to others. We do provide some of our product and service
offerings through contractual arrangements made with affiliates, service providers, partners and other third parties
(“Service Partners”). We and our Service Partners may need to use some PII in order to perform tasks between our
respective sites, or to deliver products or services to you.
We will encourage our Service Partners to adopt and promote strong privacy policies. However, the use of your
customers’ PII by our Service Partners is governed the respective privacy policies of those providers, and is not
subject to our control. Except as otherwise discussed in this Privacy Policy, this document only addresses the use
and disclosure of information we collect from your customer. Our Advertising and Service Partners, have their own
privacy policies and data collection, use and disclosure practices. We are not responsible for the policies or practices
of third parties.
Occasionally we may be required by law enforcement or judicial authorities to provide PII to the appropriate
governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or to cooperate
with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who
use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that
we in good faith believe to be unlawful.
We may also provide Aggregate Information about our customers’ sales, traffic patterns, and related information to
third party advertisers, but these statistics do not include any Personally Identifiable Information. - Security of Your PII
You can be assured that your customers’ PII is secure, consistent with current industry standards. We strive to take
appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or
destruction of PII. For example:
We also only keep collected information and use it only for the purposes for which it was
collected or to comply with any applicable legal or ethical reporting or document retention
requirements.
We limit access to PII only to specific employees, contractors and agents who have a reasonable
need to come into contact with your information. For example, we may provide members of our
technical support team with limited access to your account in order to allow them to troubleshoot.
Additionally, we also employ a number of physical, electronic, and procedural safeguards to
protect PII. Our secure servers and our data centers are protected by industry-standard encryption,
and our servers reside behind firewalls and employ high-level password protection.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.
As a result, while we strive to protect PII, you acknowledge that: (a) there are security and privacy limitations
inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all
information and data exchanged between you and us through this Site cannot be guaranteed.
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Our policy is that we do not knowingly collect, use or disclose PII about minors.
If you have any questions, concerns or inquiries about our Privacy Policy, or our use of PII, or our privacy practices,
please contact us at: privacy@aimediagroup.com. You can also reach our Privacy Compliance Officer by sending
written correspondence to:
Ai Media Group, LLC
1359 Broadway, 5th Floor
New York, NY 10018
Attn: Privacy Compliance Officer
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PROVISIONS SPECIFIC TO EUROPEAN INDIVIDUALS
The following provisions apply only to European individuals.
Who is the data controller?
For the purpose of any legislation or binding local regulations implementing the provisions of Directive 95/46/EC of
the European Parliament (the “EU Directive”), the data controller of your EEA-based customers’ Personal Data (as
defined below) is typically you. However, in the event that the EU Directive classifies the Company as data
controller in respect of your EEA-based customers’ Personal Data the remaining provisions of this Policy shall
apply.
Please note that even if the Company is not the data controller of your EEA-based customers’ Personal Data, we will
still take reasonable endeavours to ensure that we treat such Personal Data in accordance with both this Policy and
our obligations as a data processor of such Personal Data under the EU Directive.
What constitutes Personal Data?
“Personal Data” extends the definition of “PII” (as outlined above), to include any information by which an
individual can actually be identified or could be identifiable, whether simply from that information alone, or in
combination with any other information which is in our control, and includes “personal data” as defined in the EU
Directive. Each reference to PII in this Policy shall, for your customers who are based in the European Economic
Area (the “EEA”), be read as a reference to Personal Data.
Customer’s acceptance of our Policy and requests to opt out or delete.
Your customers whose Personal Data and Aggregate information we collect are required to give their consent before
we start to collect such information from them by acknowledging the notification. In addition, your customers may
opt-out of such collection at any time by using their browser to block their cookies.
You or your customers also have the right to instruct the Company to delete your PII at any time. The Company will
thereafter delete any such PII within a reasonable time after receipt and review of such request.
Should you or your customer desire to opt-out of collection or require the destruction of your PII, please send a written
request to the Company at privacy@aimediagroup.com. You or your customer’s election to opt-out of collection or to
instruct the Company to delete PII shall not affect the right to receive equal service and pricing from the Company.
Our policy towards children
In accordance with applicable European Union guidance on the practice, we do not collect or process any Personal
Data to target adverts to children. Accordingly, we do not create consumer segments that specifically target children
under 13 years old.
We store and process Personal Data outside the EEA.
Personal Data and Aggregate Information that we collect from your customers will be transferred to, and stored at, a
destination outside the EEA. It will also be processed by staff operating outside the EEA who work for us or for one
of our suppliers.
You and your customers should be aware that the data protection and privacy regulations that apply in countries
outside the EEA may not offer the same level of protection as provided for inside the EEA.
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PROVISIONS THAT APPLY WHEN INDIVIDUALS ARE BASED IN THE EUROPEAN UNION AND/OR THE
UNITED KINGDOM
The following conditions are supplemental to the terms set out above and apply only where individuals are located
in the European Union and /or the United Kingdom.
Data Protection Legislation: The General Data Protection Regulation ((EU) 2016/679), the UK Data Protection
Legislation and any other directly applicable European Union regulation relating to privacy.
UK Data Protection Legislation: any data protection legislation from time to time in force in the UK including the Data
Protection Act 1998 or 2018 or any successor legislation.
Applicable Laws means (for so long as and to the extent that they apply to the Provider) the law of the European Union,
the law of any member state of the European Union and/or UK Law.
Data Protection
We will comply with all applicable requirements of the Data Protection Legislation.
Identifying the Data Controller: For the purposes of the Data Protection Legislation, you are the Data Controller and We,
as the service provider, are the Data Processor (where Data Controller and Data Processor have the meanings as defined in
the Data Protection Legislation).
Processing: Sections 2-4 above set out the scope, nature and purpose of processing by the Us, the duration of the processing
and the types of personal data and categories of Data Subject.
Personal Data : The Data Protection Legislation extends the definition of PII (as outlined above) to include any information
by which an individual can be identified and includes location data and online identifiers. Each reference in this policy to PII
shall be taken to refer to Personal Data as defined in The Data Protection Legislation where the individual is in the EU.
Consent: in order for Us to provide You with the Services, it is necessary that the individuals in the EU have consented to
the use and processing of their Personal Data as required for US to provide the Services to you. This consent is captured when
the individual sets their privacy setting on their browser or when they acknowledge the notification that is sent to them.
Individuals may opt out or withdrawn their consent by using their browser to block cookies.
Children: EU guidelines provides that children under 13 years old cannot consent to the use of their Personal Data.
Accordingly, we do not create or use or collect identifiers that may be used to identify children under 13 years of age for the
purposes of targeting advertisements at that group.
Restrictions on Processing: We shall, in relation to any Personal Data processed by Us in connection with the performance
of our obligations under this agreement:
(a) process that Personal Data only on your written instructions and in accordance with the limits on Processing
set out above unless we are required by Applicable Laws to otherwise process that Personal Data.
(b) ensure that we have in place appropriate technical and organisational measures, to protect against
unauthorised or unlawful processing of and against accidental loss or destruction of, or damage to,
appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss,
destruction or damage and the nature of the data to be protected, having regard to the state of technological
development and the cost of implementing any measures;
(c) ensure that all personnel who have access to and/or process are obliged to keep the Personal Data
confidential;
(d) notify You without undue delay on becoming aware of a Personal Data breach;
(e) at your written direction, delete Personal Data and copies thereof on termination of the Services agreement
unless we are required by Applicable Law to store the Personal Data; and
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PROVISIONS THAT APPLY WHEN INDIVIDUALS ARE BASED IN THE EUROPEAN UNION AND/OR THE
UNITED KINGDOM
(f) maintain complete and accurate records and information to demonstrate its compliance with this clause
Transfer Outside the EEA: In order to provide you with the Services it is necessary that Personal Data and Aggregate
Information collected from individuals will be transferred to and stored by us or or suppliers outside the EEA. Whenever we
transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one
of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level
of protection for personal data by the European Commission.
(b) Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe.
(c) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield
which requires them to provide similar protection to personal data shared between the Europe and the US.
Access to Personal Information: We will assist you, at your cost, in responding to any request from a Data Subject for access
to its Personal Data and in ensuring compliance with its obligations under the Data Protection Legislation with respect to
security, breach notifications, impact assessments and consultations with supervisory authorities or regulators.
We will take all steps reasonably necessary to ensure that your EEA-based customers’ Personal Data, wherever it is
held or processed, is treated securely and in accordance with this Policy and the EU Directive.
Access to information.
The EU Directive gives your customers the right to access certain information we hold about them.
If any individual to whom the EU Directive applies wishes to request access to the information we hold about them
in accordance with the EU Directive, this access request may be subject to a fee of US $10 to meet our reasonable
costs in providing them with details of the information we hold. If wish to make such a request, please contact
privacy@aimediagroup.com.
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