SHARE LOCAL MEDIA PRIVACY POLICY
Effective Dec 26, 2024
Share Local Media is committed to protecting your privacy. This Privacy Policy explains how Share Local Media, Inc. (“Share Local Media”, “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal information in connection with our websites, including https://heypoplar.com or https://www.sharelocalmedia.com and other websites we own and operate that link to this Privacy Policy (the “Sites”), and the related content, platforms, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Share Local Media employees and other personnel.
1. HOW WE COLLECT AND USE INFORMATION
Personal Information Collected from You
The categories of information we collect submitted to us by individuals through the Services can include:
- Contact information, such as your name, phone number, email address, or mailing address, when you when you submit a request or communicate with us, such as through the “get in touch” or “request info” forms on our Sites. We use this information to provide you with products or services that you request or in which you express interest, and to communicate with you such as to send email messages.
- Account information, including first and last name, company name, employer, job title, business email address, user ID and password, profile information, affiliations, account balances, payment and purchase history information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
- Payment Information. If you sign up for one of our Services requiring payment, we collect the information provided in connection with such payment. Please note that we use third party payment processors to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice.
- Professional information you submit when you apply for a job opening, such as your work history and other information provided on your resume. We use this to evaluate your eligibility for employment.
- Other information that you provide to us online, by phone or in person, and use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.
Personal Information from Third Parties
We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.
- Data providers. To provide our Mailing Services, we may purchase or receive personal information such as name and mailing addresses, from data providers and third parties. We use this information to send Share Local Media mailings with information on new products and services offered by Share Local Media or our clients. We may combine this information with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined information.
- Service providers. Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
- Social media. When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
- Other sources. In addition to third-party data providers, we may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
In addition to the above, we may use this information to:
- To provide you with products or services that you request or in which you express interest;
- To provide, improve, test, update and monitor the services; or diagnose or fix technology problems;
- To communicate with you such as via social media and to send you email messages and notifications;
- 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 client services;
- For any other purpose we may describe when you provide the information.
Data We Process on Behalf of Our Clients to Provide Our Services. In providing our services, our clients may provide or upload data to our services, which may include personal information or data about our clients’ end users or other individuals (all of which we call “Client Data”). Client Data is owned and controlled by our clients, and any Client Data that we maintain or process we consider to be strictly confidential. We process Client Data on behalf of our clients, and solely in accordance with our agreements with our clients. Our collection, processing and disclosure of Client Data is governed by our client agreements and not by this Privacy Policy.
2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION
We, and our third-party partners, automatically collect certain types of usage information when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, 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 services, for example, the site from which you came and the site to which you are going when you leave our services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the services 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 services 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.
We use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
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.
3. SHARING OF YOUR INFORMATION
We may share your personal information with:
- Service Providers or contractors that Share Local Media uses to support the operations of our business and that perform services on our behalf, which may include sending emails, processing payments, providing append services, or providing web hosting and analytic services.
- Online advertising partners with whom we may share, personal information, or may permit they collect personal information from you directly on our websites, to facilitate online advertising on third party platforms, such as search engines and social network advertising providers to serve targeted ads to you, or to groups of other users who share similar traits, such as likely commercial interests and demographics. For more information, including how to opt out of interest-based advertising, please see Third-Party Tracking and Online Advertising below.
- 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 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 anonymized form that does not reasonably identify you directly as an individual.
- With third parties or publicly with your consent or direction.
4. CONTROL OVER YOUR INFORMATION
Email Communications. From time to time, we may send you emails regarding updates to our Service, products or services, notices about our organization, or 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 wish to unsubscribe from such emails, simply click 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).
Direct Mailings. As part of our Shared Mail Program, we send grouped promotions of our favorite companies we use and love. If you'd like to remove your address from future Shared Mail Program mailings, you may opt-out at any time by filling out the Opt-Out of Mailings form on our website. Please note, this opt-out does not affect any mailings that we facilitate on behalf of our clients, so you may still receive direct mail sent by our clients or others. You should contact the client to ask to be removed from any of their marketing, email, or mailing lists.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly using the information provided in the Contact Us section, below. We will review your request and may require you to provide additional information to identify yourself. We may not be able to modify or delete your information in all circumstances.
5. 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 services 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 services 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 services 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.
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 our services. 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.
Cookies and Other Tracking Technologies Opt-Out. As noted above, depending on your browser or mobile device, you may be able to 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 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.
6. DATA RETENTION
We will usually store the personal information we collect about you for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
7. 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.
8. INTERNATIONAL TRANSFERS
Our services 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.
9. 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.
10. CHANGES TO PRIVACY POLICY
We reserve the right to change this Privacy Policy from time to time at 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 website. It is your responsibility to review this Privacy Policy periodically. When we do change the Privacy Policy, we will also revise the “effective” date.
11. 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: Client Service - Privacy Policy Question
44 Wall St, 23rd Floor, New York NY 10005
12. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
For residents of the States of California, Colorado, Connecticut, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Nevada, Utah, and Virginia: These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal data in connection with our services, please visit our Privacy Policy. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, the Additional Disclosures set out in this Section do not describe our practices when we process Client Data as a service provider on behalf of our clients in accordance with our contractual agreements with our Clients.
Your Privacy Choices
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The Right to Know. The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you in the last 12 months, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
- The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
- The Right to Opt Out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to “sell” personal information we have collected about you to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
If you are a resident of Oregon, you also have the right to request a list of specific third parties to which we have disclosed your personal information.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
To submit a request to exercise one of the privacy rights identified above, please submit a request by:
We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Exercise Your Right to Opt-Out of Personal Information Sales or Sharing for Targeted Advertising
Unless you have exercised your Right to Opt-Out, and as described in the Disclosure of Personal Information section of these U.S. Disclosures, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.
You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
To exercise the Right to Opt-Out, you may submit a request by clicking the links below:
- Cookies-based Opt-Out (Do Not Sell or Share My Personal Information). To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please click "Do Not Sell or Share My Personal Information" below. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device.
- Opt-Out of “Selling” of Personal Information. In limited circumstances we may share your personal information (such as your name, e-mail address, postal address, and phone number) with third parties who may use such information for their own commercial or business purposes. To opt out of such sharing, please fill out our Individual Rights Request Form.
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent’s authority to act on your behalf.
For requests to know, delete, or correct personal information, we require the following for verification purposes:
- a power of attorney valid under the laws of California from you or your authorized agent; or
- sufficient evidence to show that you have:
- provided the authorized agent signed permission to act on your behalf; and
- verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the Individual Rights Request Form.
CALIFORNIA-SPECIFIC DISCLOSURES
The following disclosures only apply to residents of the State of California.
- Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, commercial information, internet/network information, geolocation data, professional/employment information and inferences generated from your use of our sites. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see How We Collect and Use Information section of our Privacy Policy.
- Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Sharing of Your Personal Information section of the Privacy Policy. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
- Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
- Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics, and market research;
- Social networks for advertising or personalization purposes, or to engage with you.
- Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
- We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Policy.
- Sales of Personal Information and Sharing for Targeted Advertising. In the previous 12 months, we have sold the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:
- Identifiers
- Commercial Information
- Internet / Network Information
In addition, please see Third-Party Tracking and Online Advertising section of the Privacy Policy to learn more about how third-party advertising networks, social media companies and other third party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us.
- Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at legal@sharelocalmedia.com to inform us if you, or your minor child, are under the age of 16.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at legal@sharelocalmedia.com. We may not be able to modify or delete your information in all circumstances.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e. you are the child’s legal guardian or authorized representative).
- “Shine the Light”. 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 share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please fill out this form.
We have determined that the value of these programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.
The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information below. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Control Over Your Information section of our Privacy Policy.
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Requests received pursuant to the CCPA from January 1, 2023 to December 1, 2023
