1.WHAT INFORMATION IS COLLECTED
We may collect several types of information about you in connection with the Services.
Information You Provide to Us. There are a number of circumstances in which you supply us with personal information in connection with the Services, which include:
- Contact data, such as your personal or business contact information such as your name, e-mail address, street address and phone number.
- Registration data, such as information you provide when you register for any of our Services or when you register for events.
- Marketing data, such as information related to your preferences for receiving communications, subscribing to our publications, newsletters and other content, completing surveys, participating in market research, and entering a contest, sweepstakes, or game relating to the Services.
- Communications, such as information you provide when you send us an email, pitch, submit content or post a comment, request for information, or otherwise correspond with us.
- Demographic information, such as your city, state, country of residence, postal code, gender and age.
- Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, social medial account ID and preferences.
- Content you choose to upload to the Services, such as text, images, audio, and video, along with the metadata associated with the files you upload.
Information We Automatically Collect About Your Use of the Services. We, our service providers, and our business providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through our websites, such as:
- Device information: We may collect device identifiers and settings such as your computer or mobile device model, IP address, other unique device identifiers, operating system version, browser type, language, and settings, and device type and settings.
- Usage information: We may collect information about the Services you use, the time, date, and duration of your use of the Services, your interaction with content offered through the Services, site engagement, search terms used, our referring website, browsing and search history, site and advertisement interactions, and software crash reports. We also collect information stored using cookies, mobile ad identifiers, and similar technologies set on your device. Our servers may automatically keep an activity log of your use of the Services. We may collect such usage information at the individual or aggregate level.
- Location information: We collect and store your device’s source IP address, which may disclose the general location of your device at the time you access the Services and precise location derived from GPS-enabled services. Advertisements and certain content may be directed to you based on this data.
Information from Third Parties. We may receive information about you from third parties and combine it with information we receive from or about you. For example:
- Information from social media websites: When you interact with any GEMG page or account on a social media platform, such as Facebook, Twitter, Tumblr, or LinkedIn, or otherwise connect your account on the third-party platform or network to your account through our sites, we may collect the personal information available from that page or platform or that you make available to us on that page or account, including your social media account ID, username, user ID, profile picture, cover photo, and networks to which you belong, friends and connections and contact information. You can read more about your choices in the “Privacy Choices” section.
- Information from publicly or commercially available sources: We may collect certain information about you the third parties, including business partners (such as advertising and joint marketing partners) data providers (such as information services and data licensors) and public sources (such as blogs, forums or social media platforms).
Other Information We Collect. We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection. You may choose not to provide us with certain types of information, but doing so may affect your experience in using the Services.
Providing the Services. We use your information to process your subscription, send you electronic newsletters, post content you submit, enable your participation in the Services, and improve the Services. We may also use your information to establish and maintain the Services, provide support, facilitate social features, enable and support security and fraud prevention features, communicate with you about the Services, and provide information about our Services. To enable us to provide these Services, we may use the information we collect to identify you across sessions, browsers, and/or devices.
Providing Customer Support Services. We may use your information in order to provide customer support to you, including without limitation any information you provide to us when you contact us by email or any other medium.
Contacting and Communicating with You about our Services. We may contact or communicate with you (by email, phone, or other medium) concerning: editorial newsletters and content; invitations to events; offers or announcements about our products or features; offers or announcements about our third party partners’ products or services; communications about your comments or information submissions; online surveys; and legal notices, policy updates, and other important information about the Services. All editorial and commercial email messages include instructions for unsubscribing from such future communications. We also provide personalized content and suggestions to you, including by email, based on your interest and preferences.
Content and Advertising Analytics. We may use your information to help us better understand your use of, and our delivery of, the Services, including content selection, delivery, and reporting; and advertising selection, targeting, delivery, and reporting.
Auditing and Tracking Our Delivery of Advertising. We may use your information to measure and report on the delivery of advertisements, including without limitation counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Delivering Emails on Behalf of Advertisers or Event Underwriters. We may use your information, including the names and email addresses provided to us when you register for our Services (including our live events), to deliver marketing communications we believe may interest you on behalf of advertisers or event underwriters regarding their products or services. (In such instances, we do not share our readers’ information directly with these companies). Many of our readers find this a valuable service. If you do not want your information used for this purpose, you can opt-out of such use by e-mailing us at [email protected] .
Facilitating Social Media Engagement. We may use your information, including information provided to us by social media platforms, to enable you to interact with any GEMG page or account on a social media platform. We may use your information to help us determine which content or advertising to deliver to you on those social media platforms.
Providing Services to our Business Customers. We may use your information to facilitate the provision of services to business customers by our business-focused divisions, including without limitation Studio 2G (our brand studio).
Learning about Our Users and Services. We conduct research on our users’ demographics, interests and behavior, including performing statistical analysis of our users and their use of the Services. We do this to optimize and improve the Services, our products, and our operations. We may use the information from one aspect of the Services for other aspects of Services. Additionally, data collected from a particular computer, browser or device may be used with another computer, browser or device that is linked to the computer, browser or device on which such data was collected.
Research, Development, and Improving the Quality of our Services. We analyze use of the Services to analyze and improve the Services and to develop new products and services, including by studying user demographics and use of the Services.
Debugging. We may use your information to identify and repair errors that impair existing intended functionality.
To Aggregate Data or Create Anonymous Data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Information Security. We may use your information to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
Compliance with Law. We may use your personal information as required by law or if we in good faith believe that such action is necessary to comply with the law or legal process.
3.HOW WE SHARE YOUR INFORMATION
As described below, our information-sharing practices vary based on the type of information and the type of recipient.
Third-Party Service Providers. Third party agents and vendors perform functions on our behalf, including, but not limited to, hosting, content syndication, content management tools, social media integration, marketing, analytics, billing and customer service. These entities may have access to personal information if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the confidentiality and security of that personal information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to GEMG.
Third Party Event Partners or Underwriters. When you register for or attend one of our live events, we may share the information you provide at registration with our event partners or underwriters. These third parties may use your information to provide you with information about their own products and services. If you do not want your information used for these purposes, you can opt-out of such use by e-mailing us at [email protected] , or calling or writing us at the contact information provided below.
Social Media Services. If you log into the Services with a social media service or if you connect a social media account with the Services, we may share information about you or your activities on that social media service, including what you view on our websites and applications, with that social media service and/or its users. Social media services will use that information based on their own privacy policies. If you do not want your information shared in this way, do not connect your social media service account with our Services.
Business Transferees. We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.
Law Enforcement, Legal Process, and Emergency Situations. In some cases, we may use or disclose your personal information to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or legal process; to protect and defend our rights or to prevent misuse of our Services; or to protect the personal safety of our employees, agents, partners, the users of the Services, or the public.
Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
For Compliance, Fraud Prevention and Safety. We may share your personal information for the compliance, fraud prevention and safety purposes.
What are Beacons? Web beacons (also called “web tags” or “pixels”) are tiny graphics or scripts that communicate information from your device to a server. Beacons can be embedded in online or mobile content, videos, advertisements, or emails. They allow a server to read certain types of information from your device, such as when you viewed the beacon (and thus the content in which it is embedded) and the IP address of the device on which you viewed the beacon. We and third parties use beacons for a variety of purposes, including to analyze the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.
What are SDKs? SDKs are third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.
For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them
The Services may contain links to other websites, mobile applications, and other online services operated by third parties, and other websites, mobile applications, and online services operated by third parties may contain links to our Services. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions of their privacy policies. Other websites, mobile applications and Services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Advertisers may use persistent identifiers, however, to track your internet usage across other websites in their networks beyond our Services. Though we restrict any attempts to re-identify this information, Advertisers may nonetheless be able to do so by combining information they collect about you when you use the Services with information about you obtained from other sources.
In general, the information collected and generated by third parties is processed and stored by the third parties and will be subject to their respective privacy policies (which we do not control and for which we are not responsible). We do not control these third parties’ tracking technologies or the information they may collect.
There are a number of ways to opt out of having your online activity and device data collected by third parties, which we have summarized below. We hope you find this information to be a helpful reference. Please note that using these tools to opt out of tracking and targeting does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will exclude you, however, from interest-based advertising conducted through participating networks and platforms, as provided by their policies and choice mechanisms.
Blocking Cookies in Your Browser. Most web browsers automatically accept cookies, but also usually allow you to modify your settings to disable or reject cookies, including cookies for interest-based advertising. If you delete your cookies or if you set your web browser to decline cookies, however, some features of the Services may not work or may not work as designed. You can usually find these settings in the Options or Preferences menu of your browser; links to instructions provided by several of the most common browsers are below. You can also learn more at www.allaboutcookies.org.
- Cookie settings in Google Chrome
- Cookie settings in Firefox
- Cookie settings in Internet Explorer
- Cookie settings in Safari web and iOS.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Advertising Industry Opt Out Tools. Many of the third party advertisers that use tracking or targeting tools in connection with our Services either directly, or are members of programs that, offer you additional choices regarding the collection and use of your information. You can learn more about the options available to limit these participating third parties’ collection and use of your information by visiting their websites:
- Opt Out of Interest Based Advertising (National Advertising Initiative)
- Your Ad Choices (Digital Advertising Alliance)
- Your Online Choices (European Interactive Digital Advertising Alliance)
- Users of our mobile apps may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.
Platform Opt Out Tools. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising.
Mobile App Tracking Opt Out Tools. You can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:
- Apple: http://support.apple.com/kb/HT4228
- Android: http://www.google.com/policies/technologies/ads/
- Windows: http://choice.microsoft.com/en-US/opt-out
Using Privacy Plug-ins or Browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
7.IMPORTANT INFORMATION FOR USERS IN CALIFORNIA
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
How We Collect, Use, and Share your Personal Information. We collect the following statutory categories (as defined by CCPA) of Personal Information:
- Identifiers (e.g., name, email address, mailing address, phone number).
- Commercial information (e.g., subscription records, site engagement).
- Online identifiers (e.g., device identifier, IP address, unique browser ID, cookies, beacons, pixel tags, account login, other unique identifiers).
- Internet or network information (e.g., browsing and search history, site and advertisement interactions).
- Geolocation data (e.g., precise location derived from GPS-enabled services).
- Professional or employment information (e.g., information you provide when you apply for a job with us).
- Education information (e.g., information you provide when you apply for a job with us).
- Protected classification characteristics (e.g., age or gender; please note that we do not intentionally collect this information, but it may be revealed in identity data or other information we collect)
- Inferences (e.g., information about your interests, preferences, and favorites).
Your California Privacy Rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. GEMG does not sell your Personal Information in the conventional sense (i.e., for money). Like many companies, however, we use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under the CCPA. You can opt out of such “sale” of your Personal Information. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
- Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
How to Exercise your California Rights. California residents may exercise the California privacy rights described above as follows:
- Rights to information, access, and deletion. To request to exercise your information, access or deletion rights:
- Email [email protected]
- Complete this online form.
- Call us toll free: 1-866-I-OPT-OUT (1-866-467-8688) and enter service code 745.
- Right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under the CCPA. You can request to opt out of such “sale” of your Personal Information here: Do Not Sell My Personal Information. Please note that you will see some advertising, regardless of your selection.
Identity Verification and Additional Information Needed to Process a Request. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Notice Regarding directionloan.us Site. In addition to our consumer-facing website, we also operate the website www.directionloan.us, which is designed solely for business use and not intended for personal or household use. Accordingly, we treat all information collected from the directionloan.us Site as pertaining to individuals acting as business representatives, rather than in their individual capacity. We do not “sell” any information collected from your use of the directionloan.us Site, as that term is defined by the CCPA.
8.USERS IN THE EEA AND SWITZERLAND
If you are a resident of the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Services.
Among EEA Users, only those users who have explicitly consented will have their personal data processed by GEMG for the purpose of ad targeting, selection, and delivery. GEMG will seek this (optional) consent from EEA users as part of any website interface through which GEMG invites EEA users to provide personal information. For any EEA User who either (a) declines to provide such consent or (b) is never presented with a request for consent in the course of his or her use of the Services, GEMG will only serve non-personalized and non-programmatic advertising, which may be targeted using coarse location data. Additionally, GEMG’s mobile apps, email communications, and other non-website Services do not process personal data for the purposes of ad targeting, selection, and delivery (either within or outside the Services).
Transfers: Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards. Our Privacy Shield Policy governs use of personal information that has been transferred to us from organizations in the EEA and Switzerland.
Your Rights: You are entitled to the rights under Chapter III of the EU General Data Protection Regulation or Section 2 of the Swiss Federal Act on Data Protection with respect to the processing of your personal data, which include the right to access and rectify and to request erasure of personal data. To exercise these rights, contact [email protected] and provide as complete a description of your request as possible.
Third Party Processing Partners: Below is a list of the third party data processing partners with which we have a direct relationship, the categories of data processing they provide to us, and links to their privacy policies (which may provide more information about their use of your data and how to exercise your rights to opt-out of that usage). Please note that this list does not include advertisers (with whom we have no direct relationship) who advertise on our websites through ad serving networks. This list was last updated on December 30, 2019; because our Services are under constant development, it may be modified and updated on an ongoing basis.
|Third Party||Processing Category|
|Information storage and access||Personalization||Ad selection, delivery, and reporting||Content selection, delivery, and reporting||Measurement|
|Amazon Web Services||Yes|
|Google Play Developer||Yes|
The Services are not intended for children under 13 years of age. We do not knowingly collect information from children under the age of 16 and we do not target the Services to children under the age of 16. If you are under 16 years of age, do not provide personal information to GEMG without providing us with consent from your parents. If we discover that a child under the age of 16 has provided us with personal information and we do not have parental consent, we will delete that child’s information as soon as reasonably practicable. If you believe that company has been provided with the personal information of a child under the age of 16 without parental consent, please notify us immediately at [email protected].
10. OTHER IMPORTANT INFORMATION
How Your Information Is Secured. The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. You need to help protect the privacy of your own information. You must take precautions to protect the security of any personal information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personal information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks.
How Long Your Information Is Stored. The time period for which we keep information varies according to the purpose for which it is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.