1.Introduction
This Privacy Policy and Cookie Statement (“Privacy Policy”) explains how UniNetworks INC processes Personal Information in relation to the Service. This Privacy Policy does not apply to websites, apps, destinations, or other offerings that we do not own or control, even if they are linked to from the Service. All capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings set forth in the Glossary.
You can access this Privacy Policy any time in the footer of the Service’s home page, or as otherwise indicated depending on the Service you are using. By registering for any aspect of the Service, or otherwise accessing, visiting or using the Service, you consent and agree to be bound by the terms of this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use the Service, or request or receive a digital Product.
In addition to reviewing this Privacy Policy, please also review our terms and conditions that may be posted elsewhere in the Service.
This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the “Last Revised” date at the beginning of this document. If we make a material change to this Privacy Policy, we will also post on the Service a prominent notice that a change was made. Continued access, visitation and/or use of the Service by you, or continued receipt of a digital Product, will constitute your acceptance of any changes or revisions to the Privacy Policy.
2. Categories of Personal Information Acquired About You
Depending on the circumstances and which Service you use, we may collect, obtain or otherwise acquire the following types of Personal Information about you, and we make and retain inferences drawn from such information:
- I) Identifiers, such as your name, signature, postal address, zip code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.
- II) Certain characteristics, such as gender, marital status, nationality, and country of origin, that are protected by applicable law.
- III) Commercial information, such as purchase history.
- IV) Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.
- V) Geolocation data, such as the precise physical location of your Device.
3. How We Acquire Personal Information
A) Personal Information You Provide. We often receive Personal Information because you provide it to us. For instance, when you enter a register and/or set up an account/profile, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Personal Information such as your age, gender, and preferences may also be requested. In addition, we may acquire your Personal Information when you contact us by e-mail, social media interaction or messaging (e.g., email, MMS, or similar technologies). We also may acquire Personal Information, when you use our “newsleatter” email service.
B) Personal Information Automatically Collected. The Service also automatically collects certain information, some of which may be deemed Personal Information. The information collected may include, without limitation, information about your Device, such as the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect such information even if the Service is not open on your Device or you’re not logged in. See Section 4 for more information on cookies and other technologies used to automatically collect information on or through the Service.
C) Personal Information Acquired Elsewhere. We may also acquire your Personal Information offline, from third parties, or otherwise outside of the Service. For example, we may purchase or otherwise acquire Personal Information from third party consumer data suppliers/resellers, data enrichment providers and aggregators, business contact databases, government entities, and our affiliates.
D) Social Network Integration. If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Service, we may receive Personal Information that has been made available to those services, including Personal Information about your contacts on those services. For example, some social networking services allow you to push Content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. You should make sure you are comfortable with your Personal Information the third party social networking services may make available to us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We treat Personal Information that we receive through third-party social networking services in the same ways as all of your Personal Information we receive through our Service (as described in Section 4 below).
E) Be Careful Publicly Posting Personal Information. Please be aware that Content and Personal Information that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all Personal Information, especially sensitive Personal Information, that you may wish to post.
4. How We Use Your Personal Information
A) Processing Your Requests. We use your Personal Information to process your request for Content, and/or to process your request for digital Product(s). For example, if you subscribe to any of our Products we may use your e-mail address to send you a confirmation notice and your mailing address to send you the Product.
B) Administering the Service. We also use and share your Personal Information for any lawful purpose in connection with administering the Service, including without limitation for customer service, to help diagnose problems with servers, to improve Products that we offer by tailoring them to perceived preferences, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users’ movements around the Service and elsewhere on the web or across apps and/ devices. Your geolocation data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location.
C) Access by Third Parties.
- I) Service Providers. We allow access to your Personal Information by Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services. For example, Service Providers help us with technical maintenance, market research, data coop management, and other advertising functionality, including OBA (as defined in Section 7 below), as well as address verification. While we may seek to require Service Providers to follow appropriate privacy policies and will not authorize them to use your Personal Information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
- II) Third Party Businesses. There are also times when you provide Personal Information to us in areas of the Service that may be managed or participated in by one or more Third Party Business(es). Moreover, we rent, sell, share, and transfer Personal Information to (i) list buyers who market their goods and services (commonly known as “list rental”); (ii) our advertising, marketing and sponsorship clients to market their goods and services; (iii) “data coops”, which are pooled databases containing the customer information of multiple publishers to enable the marketing use of such customer information by participating publishers; and (iv) consumer data suppliers/resellers, data enrichment providers and aggregators, and other entities in the online behavioral advertising ecosystem for purposes of OBA (as described in Section 7 below), data optimization, lead generation, and other data driven projects. In all such cases, the Personal Information may be used by us and by such Third Party Business(es) for their own purposes, each pursuant to its own policies. While we may seek to require Third Party Businesses to follow appropriate privacy policies, we do not bear any responsibility for any actions or policies of third parties.
- III) Related Entities. We share your Personal Information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section 4.
- IV) Categories of Third Parties. For the sake of clarity, here is a list of recipients to whom we disclose Personal Information:
- Service Providers, as described in Section 4(C)(I) above;
- Third Party Businesses, as described in Section 4(C)(II) above;
- Related Entities, as described in Section 4(C)(III) above;
- Governmental and law enforcement officials, or parties to legal proceedings, as described in Section 4(E) below.
- Persons involved in an acquisition of our business or assets, as described in Section 4(F) below.
D) Marketing Communications. We may also use your Personal Information to communicate with you about new features, events or Products offered by us and Third Party Businesses, including our advertising, marketing and sponsorship clients.
E) Health, Safety, and Legal Requests. We may access, use, and share with others your Personal Information for purposes of health, safety and other matters in the public interest. We may also provide access to your Personal Information in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use Personal Information to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.
F) Transfer or Sale of Our Business. As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Personal Information may be among the transferred assets.
G) Combining Information. We may merge, co-mingle, or otherwise combine information, including Personal Information, in furtherance of the purposes above.
5. Opt-Out of Marketing; How to Update Your Personal Information
A) How to Opt-Out of Sharing for Marketing. California residents, see Section 10(A)(II) below. For all others, if you do not wish to have Personal Information such as your name, email address, postal address or phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator by email or as described at the end of this document. But note that, in order for us to properly administer the Service, we must continue to share your Personal Information with Service Providers as described in Section 4(C)(I) above (if you object to such sharing, you should not use the Service).
B) How to Opt-Out of Marketing Messages from Us. If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. But note that you may continue to receive certain communications from us that are necessary for the Service, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.
C) How to Update Your Personal Information. If you have registered or created an account on any part of the Service, please use the mechanism or contact information on the Service that allows you to change or update your member preferences, if available, to keep all such Personal Information accurate and up-to-date. If no such mechanism or contact information is available on the Service, contact our Privacy Policy Coordinator with your changes by email or as described at the end of this document.
6. Cookies and Related Technologies; Do Not Track (DNT)
A) Cookies/Local Device Storage. The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Businesses may independently use Local Device Storage in connection with the Service in a way that collects Personal Information for the purposes described in the respective privacy policies, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control and tailor the display of ads to you based on your preferences, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage.
B) You May Disable Local Device Storage. If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.
C) Tracking Technologies. In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”) on the Service, including in our communications with you, such as within e-mail and text messages and push notifications. We and Third Party Businesses use Tracking Technologies to determine which messages have been opened by recipients, and for all or some of the same lawful purposes described above for use of Local Device Storage.
D) Do Not Track (DNT). Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitor’s browser. As discussed below, you may opt out of the use of your Personal Information for online behavioral advertising by third parties at any time. To find out more about DNT, please visit www.allaboutdnt.com.
7. Online Behavioral Advertising (OBA) and How to Opt-Out of OBA
A) How OBA Works. We and our Service Providers, as well as Third Party Businesses, use Tracking Technologies on the Service for purposes of “online behavioral advertising” (OBA). OBA allows the serving of advertisements tailored to perceived interests inferred by your browsing on the Service and on other sites, applications, destinations, and services, using the same or a different Device. To enable OBA, we (and our Service Providers on our behalf), as well as Third Party Businesses, to collect certain information, some of which may be deemed Personal Information, including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier, online identifier) and geographic location of your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Businesses is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith.
B) Opt-Out of OBA. If you do not want OBA, you may be able to opt-out by visiting www.aboutads.info, www.networkadvertising.org, www.youronlinechoices.com/uk/ and/or by clicking the “Ad Choices” icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Businesses across this Service and other sites, applications, destinations, and services, and not tracking among pages within the Service itself. Residents of the European Economic Area (EEA) and Switzerland have additional options as described below in Section 9(B) to exercise choices with respect to OBA. Residents of California have additional options as described below in Section 10(A)(II) to exercise choice with respect to OBA.
8. Transfer of Your Personal Information Among Jurisdictions
Your Personal Information may be processed, transferred to, and maintained on, servers and databases located within the U.S. and elsewhere where the privacy laws may not be as protective as your jurisdiction. We reserve the right to transfer your Personal Information to and from any state, province, country or other governmental jurisdiction. Your consent to this Privacy Policy followed by your submission or our collection of such Personal Information represents your agreement to any such transfer.
9. Information Security and Notification
A) Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.
B) No Liability for Breach. Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of your Personal Information or the security of servers, networks or databases, and by using the Service you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.
C) Breach Notification. In the event that we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you.
