Effective date:? 1/1/2020
THE PURPOSE OF THIS POLICY
Your privacy is important to us, and so is being transparent about why and how we collect information about you, how we use and share it, how we protect it, and your right to have your personal data deleted.
Your Rights to Accessing, Removing, and Limiting Your Data On Our Systems
Accessing Your Data on Our Systems
You may request a copy of all of your personal data in our databases and systems by emailing email@example.com, or sending a written request to us at: 3Q Digital ATTN: Personal Data Access 25 E Washington Street, Suite 420, Chicago, IL 60602, USA. We will respond with a copy of any and all of your personal data on our systems and our partner processors’ systems within 30 days.
Removing Your Data From Our Systems
You may request that we delete all of your personal data in our databases and systems by emailing firstname.lastname@example.org, or sending a written request to us at: 3Q Digital ATTN: Right to Be Forgotten 25 E Washington Street, Suite 420, Chicago, IL 60602, USA. We will respond and delete your personal data from our systems and our partner processors’ systems within 30 days.
You may unsubscribe from our marketing communications at any time by clicking the unsubscribe link at the bottom of a 3Q Digital marketing email, by emailing us at email@example.com, or by sending a written request to us at: 3Q Digital ATTN: Unsubscribe/Opt-Out Request 25 E Washington Street, Suite 420, Chicago, IL 60602, USA. If sending a written request, please include the email address that you wish to have unsubscribed. You may also opt out of the collection of interest-based advertising data by members of the Digital Advertising Alliance by visiting the Consumer Choice Page at www.aboutads.info/choices, and from members of the Network Advertising Initiative by visiting www.networkadvertising.org/choices.?
We collect three different types of data: personal information, non-identifiable basic information and? non-identifiable cookies.
We collect your name, email address, phone number and company when you fill out our Contact Us form or when you request content through our website.
Non-identifiable Basic Information
We collect click-stream data, HTTP protocol elements, approximate location, time zone, and search terms. We use this data for research and development, system tracking, helping visitors reach the right page, and to inform future content. This data is non-identifiable. This means we can’t (and have no interest in trying to) use it to identify you or any individual person. We also collect access logs and search strings to improve our site.
Non-identifiable Cookie Information
We collect HTTP cookie data. Again, we use this data for research and development, system tracking, helping visitors reach the right page, and to inform future content and to improve our site. Our cookies are non-identifiable, meaning we can’t (and don’t want to) use them to identify you or any individual person.
A cookie is a piece of information sent to a browser by a web server. The browser then returns that information to the web server. This is how some web pages “remember” your previous visits; for example, an e-commerce site might use a cookie to remember which items you’ve placed in your online shopping cart. Cookies can also store user preference information, log-in data, etc. Cookies let sites provide you with tailored information.
For additional information on the types of cookies we use or directions on how to withdraw or change your consent, please see our Cookie Declaration.
We do not share your personal data with anyone outside of 3Q Digital, other than our vendors, which help us operate our business and provide our services.? We will disclose personal information in response to lawful requests by public authorities to meet national security or law enforcement requirements.? We may also transfer the information we hold in the event we sell or transfer all or a portion of our business or assets (such as in connection with a merger, acquisition, reorganization, dissolution or liquidation) or take steps in anticipation of such a transaction.? We analyze non-identifiable information with Google Analytics for internal use only in order to improve the effectiveness of our website.
If you are a California resident, we provide additional information about our information practices and you may have certain rights with respect to your information. For more information, please see the Supplemental Privacy Notice for California Residents below.
EU-U.S. Privacy Shield
In compliance with the Privacy Shield Principles, 3Q Digital commits to resolve complaints about our collection or use of your personal information.? EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact 3Q Digital at:
Phone: +1 (650) 539-4124
Mail: ?3Q Digital, 25 E Washington Street, Suite 420, Chicago, IL 60602, USA
?3Q Digital has further committed to refer unresolved Privacy Shield complaints to JAMs, an alternative dispute resolution provider located in the United States. ?If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit the JAMs website at https://www.jamsadr.com/eu-us-privacy-shield?. ?The services of JAMs are provided at no cost to you.
An individual may initiate binding arbitration, subject to the pre-arbitration requirements of direct request to 3Q Digital and JAMs above, by delivering a “Notice” to the organization.? The Notice shall contain a summary of steps taken to resolve the claim, a description of the alleged violation, and, at the choice of the individual, any supporting documents and materials and/or a discussion of law relating to the alleged claim.
The Federal Trade Commission has jurisdiction over 3Q Digital’s compliance with the Privacy Shield.
3Q Digital commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
The provision regarding liability for the actions of agent processors does not apply because 3Q Digital does not transfer personal information to third parties.
Links to Other Sites
Our sites link to and redirect to third-party websites. We’re not responsible for the privacy practices or the content on those sites.
We use data hosting service providers in the United States to host the information we collect. ?We take technical and organizational measures to keep your data safe from loss, tampering, misuse, and unauthorized access.? However, no method of transmission over the Internet, or method of electronic storage, is absolutely secure. Therefore, while we strive to protect your information, we cannot guarantee its absolute security.
SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
SUMMARY OF INFORMATION WE COLLECT
If you are a California resident, California law requires us to provide you with additional information about how we collect, use, and disclose your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
How we use these categories of personal information.? We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial (as those terms are defined in applicable law): ?
Our or our service provider’s operational purposes;
Auditing consumer interactions on our site (e.g., measuring ad impressions);
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection and error reporting;
Customizing content that we or our service providers display on the Services (e.g., contextual ads);
Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features) ;
Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
Other uses about which we notify you.
Sale of personal information.? The CCPA sets forth certain obligations for businesses that “sell” Personal Data.? Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity.? We do allow certain third parties to collect certain information about your activity, for example through cookies, as explained in our
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law provides you with a number of rights regarding your personal information.?
Access.? You have the right to request a copy of certain information we hold about you, as well as a summary of the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or sharing that information; and the categories of third parties with whom we shared that information.?
Delete.? You have the right to delete certain information we have about you.?
Financial Incentives.? You have the right to receive information about the financial incentives that we offer to you (if any).
Consequences for Exercising Rights.? You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.?
Shine the Light.? You also have the right to request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
Certain information may be exempt from these rights under applicable law. For example, we need certain types of information so that we can provide you with the Service. If you ask us to delete it, you may no longer be able to access or use the Service.
You can exercise any of these rights by emailing firstname.lastname@example.org, or sending a written request to us at: 3Q Digital ATTN: Personal Data Access 25 E Washington Street, Suite 420, Chicago, IL 60602, USA. You may need to give us enough information so that we can be confident of your identity before we can satisfy certain requests.? To do that, you’ll need to give us certain information about you and/or your use of the Services.? You can also designate an authorized agent to make a request on your behalf.? To do so, you have to give us written authorization for the agent to act on your behalf.? If we need to verify your identity, you’ll need to do that directly with us.