Last updated: February 13, 2020
Our Commitment to You
Empire Media Network Ltd. and its affiliated companies (“Empire Media”, “us” or “we“) are dedicated to providing its users with the highest level of transparency and control over the use of their data. In order for us to provide you with our services, we are required to collect and process certain personal information about you and your activity.
By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of this Information. We encourage you to review the following information carefully.
Grounds for data collection
Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services and the operation of our websites (hereinafter the “Websites” and “Service“), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
How do we receive data about you?
We receive your Personal Data from various sources:
What type of data do we collect?
In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy. We collect the following Personal Data about you:
Please note that although registration is not mandatory, unregistered users may have limited usage of the Service.
We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.
When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, beacons and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Web site’s performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.
What are cookies?
Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.
Cookies are widely used in order to make websites work in an efficient way. Cookies remember your preferences and make the interaction between you and the Service smoother and more efficient.
How to manage your cookie settings?
There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
For other browsers, please consult the documentation that your browser manufacturer provides.
How do we use the data we collect?
Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
With whom do we share your Personal Data?
EU User Rights
You may request to:
However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.
Transfer of data outside the EU
EU users – please note that some data recipients may be located outside the EU. In such cases, we will transfer your personal data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
Collecting Personal Data
In the preceding twelve (12) months, we have collected the following categories of Personal Data:
|Category of Personal Data Collected||Personal Data Collected||Sources of Personal Data||Business/Commercial Purpose for Collection|
|Identifiers||Full name, email address, IP address, UDID, social network account, Advertiser Identifiers||
Directly from consumers upon subscription.
Directly from consumer’s activity on our Services by cookies or other tracking technologies.
From third parties that interact with us, including social networks and other publicly available sources.
To provide you with our Service.
To announce news or updates regarding our Service.
To conduct surveys or test new features to improve our Service.
For marketing or advertising purposes.
|Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))||Telephone number|
Sharing Personal Data
We disclose your Personal Data to third parties for a business purpose (as it is defined under the CCPA). When we disclose Personal Data for a business purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Data confidential and not use it for any purpose except in the performance of the contract.
In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Data with the following categories of recipients for a business purpose:
Selling Personal Data
We share some of your Personal Data with our partners to provide our Services and for other commercial purposes. Under the CCPA some of this sharing may be considered a “sale” that you have a right to opt-out of.
If you choose to opt-out of sale, such action may impact how you are able to view and/or receive some services. This is because some of the services we offer require disclosure of your Personal Data to third parties.
In the preceding twelve (12) months, we have sold the following categories of Personal Data:
You have the right to opt-out of such disclosures of Personal Data, see below for more information on how to exercise your rights.
User Rights under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Data
You may request that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.
You have the right to submit a verifiable consumer request that we delete Personal Data collected from you and retained
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
Right to Opt-Out of the Sale of Personal Data
In the event that we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Data” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data (except for Personal Data sold within 90 days prior to your exercising your right to opt-out) or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# and the information provided above in the “Tracking Technologies” section of this policy.
Exercising Your Rights
You can exercise your rights by submitting a verifiable consumer request to our email address: email@example.com.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Data.
The request must:
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Data that we collect about you and how we use it, please contact us at firstname.lastname@example.org.
Response Timing and Format
Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
How do we protect your information?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access to your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.
We will retain your Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
How to contact us?
If you wish to exercise any of the aforementioned rights or receive more information, please contact us using the details provided below:
Our Policy Toward Children
We understand the importance of protecting children’s privacy, especially in an online environment. The Site and Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.
Updates to this Policy