SHARE LOCAL MEDIA SERVICES PRIVACY POLICY

Effective Date: November 14, 2018

Welcome to Share Local Media, Inc. (“Share Local Media,” “we” or “us”).  This Services Privacy Policy explains how we collect, store, use, and share the personal information we acquire on our behalf through our Services or on behalf of our Clients through the provision of our Services, or through other sources. 

Specifically, this Services Privacy Policy applies to: 

  • Personal information we process from companies who engage with us such as startups, technology companies, and brands (“Clients”), potential Clients, or any other third-party who may engage with us in relation to (a) our services offered through our Site, (b) our SaaS marketing platform, (c) our stand alone direct mail marketing services or campaigns,  (d) our Shared Mail Program, and (e) any other services related to the development or management of  products and services in connection with our direct mail marketing campaigns (“Services”). 

  • Personal information we process from individuals (“Consumers”) that was collected through relationships we have with other companies such as data suppliers, business partners (such as ad networks and other online partners), data services providers, and agencies.

  • Personal information we process on behalf of our Clients through the provision of our Services (“Client Data”). 

If you are one of our Clients, by using our Services, you consent to our collection, storage, use and disclosure of personal information as described in this Services Privacy Policy and our Terms of Use

This Services Privacy Policy does not apply to personal information that is collected, stored, used, or disclosed by us when individuals visit our website https://www.sharelocalmedia.com (our “Site”). For information on how we collect, store, use, or share individuals’ personal information acquired through our Site, please see our Website Privacy Policy.

Click on the links below to jump to each section:

  1. Information We Collect

  2. Cookies and Other Tracking Technology We Use to Collect Information

  3. How We Use Your Information

  4. How We Share Your Personal Information

  5. Control Over Your Information

  6. Third Party Tracking and Online Advertising

  7. Data Retention

  8. Confidentiality and Security

  9. Links to Third Party Websites

  10. International Transfers

  11. Share Local Media’s Relationship With Clients

  12. Children’s Privacy

  13. Your California Privacy Rights

  14. Changes to Privacy Policy

  15. Questions and Suggestions

1. INFORMATION WE COLLECT

We collect personal information in a variety of ways. For example:

  • Information you provide directly to us.  We collect information that you provide to us when you set up an account with us, use or purchase our Services, or communicate with us.  For example, we may request your personal information (e.g., name, postal address, email address, telephone number, payment information, ) or your applicable business information when you register or fill out forms on our Site, purchase services, or communicate with us, as well as any information you provide if you take part in any interactive features of the Service (e.g., promotions, surveys, etc.).  Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you.  

  • Information from other sources. We may receive information about you from our partners including, but not limited to distribution partners, investors, Clients, data services, and marketing firms. We may combine this information with other information we collect from or about you. In these cases, our Services Privacy Policy governs the handling of the combined information.  

  • Consumer Information. If you are a Consumer, we may receive data from a variety of sources including consumer-facing companies, services, data compilers, and suppliers. We may also obtain data from public sources, such as the US Census and other public records. Some of the data we receive, use and make available is personal information or is linked to personal information. Personal information may include name, postal address, telephone number or email address.

  • Client Data.In providing our Service, we collect information on behalf of our Clients, which could include personal information of our Clients’ existing and potential clients, contacts and end users (all of which we call “Client Data”). We may collect personal information, including name, email address and contact information, when our Clients upload or otherwise provide us with contact lists of existing and potential clients.   We may combine this Client Data with personal information we receive from third party sources, such as data services, address look-ups, promotional partners and other third-party partners, as part of our Services offered to our Clients. We collect, store, use, or disclose Client Data as authorized or required by our Clients, or as provided for in our agreements with our Clients. 

For more information about your communication preferences, see “Control Over Your Information” below.

2. COOKIES AND OTHER TRACKING TECHNOLOGY WE USE TO COLLECT INFORMATION

We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us.  We typically collect this information through a variety of tracking technologies, including cookies, locally stored objects (LSOs) such as HTML5, web beacons, file information and similar technology (collectively, “tracking technologies”). 

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

  • Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. 

  • Information about the way you access and use our Sites, for example, the site from which you came and the site to which you are going when you leave our Sites, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Sites from multiple devices, and other actions you take on the Sites. 

  • Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address. 

Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

Cookies Opt-Out. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Services, as some features and services may not work properly.  Deleting or blocking cookies does not delete Local Storage Objects (LSOs) or similar technologies that do not rely on cookies.   You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. 

Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. 

We and our third-party partners may also use cookies and tracking technologies for advertising purposes.  For more information about tracking technologies, please see “Third-Party Tracking and Online Advertising” below.

3. HOW WE USE YOUR INFORMATION

We may use your information, including your personal data, as follows:

  • To provide you with products or services that you request or in which you express interest, including for billing purposes and to process your payments;

  • To enable you to participate in interactive features of the Services (such as engaging in surveys or promotions);

  •  To remember your information so you will not have to re-enter it during a subsequent visit; help you efficiently access your information after you sign in; provide, improve, test, update and monitor the Site or the Services; or diagnose or fix technology problems;

  • To help our Clients and other marketers customize, target, and deliver direct marketing campaigns; 

  • To provide software updates, product support, product enhancements and other services to you related to the Services or the Site;  

  • To improve, market or promote Share Local Media’s products and services;

  • To contact you, including about the Services or your account;

  • To customize the advertising and content you see;

  • To alert you to product upgrades, special offers, updated information and other new products and services offered by Share Local Media, our Clients and our third-party partners;

  • To respond to your emails, comments, questions or requests for customer service;

  • For any other purpose we may describe when you provide the information.

4. HOW WE SHARE PERSONAL INFORMATION

We may share personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below. 

We may share personal information that we collect with: 

  • Agents, vendors or contractors that Share Local Media uses to support the operations of our business and that perform services on our behalf, which are subject to reasonable confidentiality terms and may include serving targeted advertisements, sending emails, processing payments, providing append services, or providing web hosting and analytic services. 

  • Third party providers with whom we engage to provide Services to our Clients. These service providers may use personal information only for the purposes for which it is disclosed to them and are required to keep the information confidential unless disclosure is reasonably necessary to perform the service. 

  • Our Client to provide our Services for that Client.  We do not share one Client’s Data with any other Client, except at the direction of our Client and/or in accordance with our Client agreement. While we require our Clients to process Client Data we collect on their behalf in accordance with the terms of this Privacy Policy, our Clients may have their own privacy policies which may also govern their use of the personal information they collect. 

  • Third parties for marketing purposes.

  • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or other agreements or to protect the security or integrity of the Share Local Media Services, including to prevent harm or financial loss, or in connection with preventing fraud or illegal activity; and/or (c) to exercise or protect the rights, property, or personal safety of Share Local Media, our Clients, visitors, or others.

  • Other parties in connection with a transaction or potential transaction where Share Local Media merges with another organization, files for bankruptcy, or sells some or all its assets or capital stock.

  • With other companies and brands owned or controlled by Share Local Media, or under common ownership and control as Share Local Media. These companies will use your personal information in the same way as we can under this Policy.

  • With others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. 

We are not responsible for the information Clients share with other Clients directly, or with any third parties, and we encourage Clients to become familiar with third party privacy practices before disclosing personal information to third parties. 

5. CONTROL OVER YOUR INFORMATION

Modifying Account Information. If you are one of our Clients and you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through options provided on the Service.  In addition, you may request to modify certain information associated with your Share Local Media account where it is incorrect or incomplete at any time by contacting Share Local Media and describing the change you would like to make; however, we cannot guarantee that all such requests will be accommodated. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below. 

Please note that Share Local Media does not own or control the Client Data uploaded to our Service by our Clients and cannot modify or delete Client Data except at the request of our Client, or as permitted by our Terms of Use. 

Unsubscribing from Our Email Communications.  From time to time, we may send you emails regarding updates to our Service, products or services, notices about our organization, or other service related communications. We may also send you commercial emails with information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you, including emails on behalf of one of our Clients. If you have an account through our SaaS service, you may unsubscribe from commercial emails through your account preferences. You may also unsubscribe by clicking the “unsubscribe link” provided at the bottom of the email communication.  Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices). 

Opting Out of Our Shared Mail Program Mailings.Through our Shared Mail Program, we mail Consumers promotions of our favorite companies we use and love, but if you'd like to remove your address from future mailings, you may opt-out at any time by filling out the “Opt-Out of Mailings” form on our Site. 

If you decide to opt out, we will suppress your mailing address from receiving Share Local Media’s Shared Mail Program mailings. While we will process your opt out request within 10 business days, please note that we are unable to stop mailings that are already in progress. We are not responsible for typographical differences in the way your address may be included in our system, so please ensure that you enter the mailing address exactly as it appears on the mailing you received from us in your opt out form request. Finally, please note that opting out in this fashion will not opt you out of our Clients’ mailing lists, only from our Shared Mail Program, so other companies that we work with may continue to send you ads and content. 

6. THIRD-PARTY TRACKING AND ONLINE ADVERTISING

We may share, or we may permit third-party online advertising networks, social media companies and other third-party services, to collect, information about your use of our website over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information.  This information is used to display targeted ads on or through our Site or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service or our Clients’ services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device.  You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).  Please note that opt-outs are browser specific, so opting out on one browser will not affect a second browser, or device. Moreover, if you buy a new device, use a different browser, or clear all your cookies, you will have to opt out all over again. 

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.  

Google Analytics and Advertising.We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Sites. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

7. DATA RETENTION

We may retain your information as long as appropriate for business purposes, unless we are required by law or regulation or for litigation and regulatory investigations to keep it for longer periods of time. Any personal information that we have acquired, either directly or from third parties, and that is no longer needed for any business or record-keeping purposes, is disposed of securely and in compliance with established best practices for secure data destruction and/or deidentification.  Any Client Data that we have collect on behalf of our Clients shall be retained, stored, and deleted according to our contract with our business Clients. 

8. CONFIDENTIALITY AND SECURITY

We maintain commercially reasonable physical, electronic, and procedural safeguards designed to protect the information. These safeguards include storing your information on our secure servers behind firewalls. Despite the actions and precautions we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of the information and you acknowledge and agree that you transmit it to us at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations. 

Each Client will remain responsible for the privacy and security of the Client Data that it collects and processes and for compliance with applicable data protection laws that may apply to its collection, processing and disclosure of Client Data through the Services.

9. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

For your convenience, our Service may provide links to third-party websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.

10. INTERNATIONAL TRANSFERS

The Services are generally intended for United States residents. We store data on servers in the U.S. or any other country in which Share Local Media or its affiliates, subsidiaries, agents or contractors maintain facilities. 

11. SHARE LOCAL MEDIA’S RELATIONSHIP WITH CLIENTS

Share Local Media is a party to a contract with each Client, under which the Client agrees, among other things, to abide by this Privacy Policy.  Share Local Media is not liable for any acts or omissions of its Clients or their employees, agents, or affiliates, including any collection, use and sharing of information by Clients in violation of this Privacy Policy.  Share Local Media and its Clients are independent contractors. No Client has any authority to assume any obligation on behalf of Share Local Media.  

12. CHILDREN’S PRIVACY

Our Services are not intended for children under the age of 13. We do not knowingly solicit or collect personal information from children under the age of 13.  If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible.  If you believe that we might have collected information from a child under 13, please contact us at legal@sharelocalmedia.com.

13. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits visitors that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at legal@sharelocalmedia.com.

14. CHANGES TO PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time in our sole discretion.  We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Share Local Media account and/or by placing a prominent notice on our Site.  It is your responsibility to review this Privacy Policy periodically. When we do change the Privacy Policy, we will also revise the “effective” date.

15. QUESTIONS AND SUGGESTIONS

If you have any questions regarding this Privacy Policy, or any of our services, please send an email to legal@sharelocalmedia.com, or contact us at:

Share Local Media

ATTN: Customer Service - Privacy Policy Question

85 Broad St, 30th Floor, Suite 102

New York, NY 10004