document: title: privacy policy
text: Privacy Policy

PLEASE NOTE THAT OUR PRIVACY POLICY CHANGES PERIODICALLY AND IS EFFECTIVE AS OF MAY 25, 2018.

Digital First Media (“Digital First Media,” “us,” or “we”) is committed to protecting your personal privacy. We provide this Privacy Policy (“Policy”) to explain the type of Personal Information (as defined below) we collect on web sites including SMS/Text Alerts and Mobile Web owned by the Digital First Media, such as www.digitalfirstmedia.com (each, a “Web Site”), and our mobile application (the “Application,” together with Web Site, the “Platform”) and how we use Personal Information. As we update and expand our Platform and services, our Policy may change so check back to this page from time to time.

Our Policy applies to Personal Information that you may provide to us, or that we may obtain, through our Platform, or in other ways such as by phone, by mail, or through other offline and print media. This Policy does not apply to Personal Information collected about you by anyone except us and only applies to the Platform or Web Site to which this Policy is linked.

Types of Information We Collect

In order to make your visits to our Platform and use of the services available on or through our Platform as worthwhile as possible, we may ask you for Personal Information. “Personal Information” is information that allows someone to identify or contact you. We also may collect certain information from your computer each time you visit us that is not Personal Information. For example, non-user specific aggregated data such as information about traffic patterns on the Web Sites.

What Information is Collected on Our Platform

Information You Provide. We collect Personal Information when you provide it to us on our Platform. Such Personal Information may be collected, for example, when you submit a comment or question to us using a “contact us” or similar feature on our Platform, send us an e-mail, sign up for an email newsletter or mobile alerts, or in any other way submit information to us via our Platform.

You may be able to send products, services, or information to others through our Platform by clicking on an “E-mail to Friend” or similar button on our Platform or in an e-mail that we have sent you. In some of these cases (unless you simply forward our e-mail on your own), you may provide the name and e-mail address of your friend or family member to us. Such Personal Information will be treated in accordance with our Policy and applicable law.

Cookies. We may use “cookies” to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser when you visit a site that are stored on your device. Cookies improve and personalize your experience on our Web Sites. You may occasionally get cookies from our advertisers. We do not control these cookies, and these cookies are not subject to our Policy. Some web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Refusing a cookie may negatively impact the display or function of the Web Site. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, Digital First Media does not modify your experience based upon whether such a signal is broadcast.

Clear GIFs. We may use clear GIFs (a/k/a “web beacons” or “pixel tags”) or similar technologies on our Web Site and in our communications with you to enable us to know whether you have visited a Web Page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, enabling the verification of an individual’s viewing or receipt of a web page or message.

Network and Internet Information. Our server may automatically collect data about your server’s internet address when you visit us. This information, known as an Internet Protocol Address, or IP Address, is a number that is automatically assigned to your computer by your internet service provider whenever you’re on the internet. We may also collect the referring page that linked you to us or the next site you visit; how you use or interact with our Web Site; technical information and specifications about your browser, device, software and settings; any search terms you have entered on our Web Site or a referral site; and other web usage activity and data logged by our web servers.

How is Information Used

We use both Personal Information and non-personal information for multiple purposes, including:

  * Improving or customizing the Web Site;
  * Providing updates;
  * Sending newsletters, promotional offers or opportunities regarding new services, products or events, and third-party products or services, including advertisements;
  * Responding to your requests including providing you with our product and service offerings;
  * Internal record keeping;
  * Reporting Personal Information about your account to credit bureaus (such as late or payments, missed payments, or other defaults on your account may be reflected in your credit report);
  * Communicating with you about, and administering your participation in, promotions, surveys and market research;
  * Operating, evaluating, and improving our business;
  * Diagnosing problems with our Platform, administering our Platform, and enhancing the Platform;
  * Monitoring the usage and performance of our Platform;
  * Improving and analyzing our products and services;
  * Managing our communications; and
  * To protect against fraud and identity theft and comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms of Use.



Sharing of Your Personal Information

Social Networking. The Platform may offer you the ability to share your Personal Information through a social networking site (e.g., Facebook, Twitter, LinkedIn). The use of such integrated tools enables you to share Personal Information about yourself with other individuals or the public through the social networking site, but is not governed by this Policy. For more information about the privacy practices those social networking sites, please visit the privacy policies of the entities that provide these social networking sites.

Third Party Offers. We may, from time to time, provide your Personal Information to third parties so that they may send you these offers. Please note that we are not responsible for and do not have access to correct any Personal Information that is maintained by Digital First Media affiliates or other entities unaffiliated with Digital First Media. In addition, we also do not manage the unsubscribe process for various third party entities and Digital First Media affiliates. You should contact the respective Digital First Media affiliate or the third party entity for more information relating to their unsubscribe process or correction or removal of your Personal information.

Co-sponsored Contests, Sweepstakes and Offerings. Some of our contests, sweepstakes and other offerings may be co-sponsored by another company. In those situations, your Personal Information may be shared with our co-sponsor. Their use of information you provide to such third parties is not governed by this Policy but instead by that company’s privacy policies.

Service Providers. We may use service providers to help operate our Platform and deliver our products and services, and may share your Personal Information with those service providers. Some examples of services provided by our service providers include web site or database hosting, address list hosting, e-mail, analytics, payment, distribution, and fulfillment.

Disclosures Without Your Consent. We may disclose Personal Information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your Personal Information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.

Disclosures With Your Consent. We may ask if you would like us to share your Personal Information with other unaffiliated third parties who are not described elsewhere in this Policy.

Business Transfer. We may share your Personal Information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share your Personal Information with that company.

Third Party Advertising. We may use third party advertising companies to serve ads when you visit our Platform. These companies may use Personal Information (generally, not including your name, address, e-mail address or telephone number) about your visits to this Platform and to other web sites in order to provide advertisements. These companies may employ cookies and clear GIFs to measure advertising effectiveness. We encourage you to read the privacy policies of these third party ad servers. If you would like more information about this practice and to know your choices about not having Personal Information used by these companies, see the Network Advertising Initiative’s consumer web site at www.networkadvertising.org/consumer/. Digital First Media participates in behavioral based advertising. This means that a third party may use technology (e.g., a cookie) to collect Personal Information about your use of the Platform so that they can provide advertising about products and services tailored to your interests. This advertising may appear either on the Platform, or on other sites.

Public Forums. We may offer public chat rooms, bulletin boards, and comment submission forms. Please note that information that you disclose in these public forums become public and may be associated with your name and that by submitting information to these public forums, you consent to sharing such information publicly.

Affiliates and Acquisitions. We may share your Personal Information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share your Personal Information with that company.

Your Rights

Objection and Opt-Out. Depending on applicable law, you may have the right to “opt-out” or object to certain of our uses of your Personal Information at any point. For example, at the time you are requested to provide Personal Information on this Platform, you may have the opportunity to elect to (or not to) have your Personal Information used in certain ways. You may also make this request by contacting us using the information in the “Contact Us” section. In this e-mail, please indicate whether you would like to opt-out of (i) receiving any correspondence from us or from entities affiliated with us or unaffiliated third parties for their marketing purposes; or (ii) opt-out of only specific uses of your Personal Information. You may also opt-out of promotional e-mails by clicking on an opt-out link within the e-mail you received. In some cases, we may no longer be able to provide you services if you opt-out of certain necessary processing.

Changing Your Personal Information. You may request your Personal Information be updated or changed. Some of our Web Sites may allow you to do so directly. Note that we may keep historical information in our backup files as permitted by law.  

Deletion. Digital First Media generally keeps your Personal Information for as long as is required for the purpose it is collected, unless a longer retention period is required or permitted by law. You may, however, request that we delete your Personal Information. We may also decide to delete your Personal Information if we believe it is inaccurate, incomplete, or that our continued use or storage of the information is prohibited by our obligations to other parties. When we delete Personal Information it will be removed from active databases but may remain in archives where it is not practical or possible to delete it. In addition, we may keep your Personal Information as needed to comply with legal obligations, resolve disputes, or enforce agreements.

Transmission of Personal Information to Other Countries. Your Personal Information may be processed in the United States, where privacy laws may be less stringent than the laws in your country. By submitting your Personal Information to us you agree to the transfer, storage and processing of your information in the United States.

Complaints. We take your privacy seriously and hope you will use the information in the Contact Us for your questions and concerns. You may also have the right to complain to regulatory bodies about our privacy practices.

Protecting Information

No transmission of data over the internet or electronic storage of data is completely secure. Digital First Media takes reasonable steps to protect the security and integrity of all Personal Information provided to this Platform, but we cannot guarantee that Personal Information, during transmission through the internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

In the unlikely event that we believe that the security of your Personal Information may have been compromised, we may notify you of that development. If a notification is appropriate, we endeavor to do so as promptly as possible under the circumstances, and we may notify you by any method permitted by law.

Children

Digital First Media does not knowingly collect Personal Information from children under the age of 13. No one under age 13 is authorized to provide any Personal Information to us or use our Platform.

Third Party “Linked-To” Web Sites

When you are on our Platform you may have the opportunity to visit, or link to, other web sites not operated by Digital First Media, including other web sites operated by our affiliates, by service vendors, or by unaffiliated third parties. These web sites may collect Personal Information about you. Digital First Media does not control web sites that are operated by these entities and is not responsible for the information practices of these web sites. The privacy policies of web sites operated by other affiliates of Digital First Media are located on those web sites.

Applicant and Employee Information

If you submit an application for employment to or are currently an employee of Digital First Media, Digital First Media collects your Personal Information through your application for employment or during continued employment with Digital First Media, and your submission of employee related documents (collectively “Employee Information”). Examples of Employee Information that may be collected in connection with your employment or application for employment include your name, date of birth, government issued identification, banking information, marital status, health information, benefit information, employment history, education, job qualifications, and other relevant employee personal data. We also collect some of this information about your dependents when you provide it to us when you enroll in health and other benefits or provide contact information. By providing Personal Information about family members or other individuals, you represent that you have their consent to provide this information to us for the purposes set forth in this Policy. Employee Information does not include any Personal Information that is available to the general public and excludes information generally available on a business card.

In accordance with applicable law, Digital First Media may use Employee Information to evaluate applications for employment, manage work-related aspects of the employee-employer relationship (i.e., training, payroll, benefits, travel, reimbursement expenses, performance appraisals, succession planning, team member health and safety), investigate and respond to any claims related to your employment, and comply with applicable laws and regulations. Your Employee Information will not be used for direct marketing purposes by us or any third party service provider, unless you specifically consent to such use.

Digital First Media shares your Employee Information with third parties who provide outsourced human resource functions to us. Digital First Media may disclose your Employee Information if required or permitted to do so by law (such as when part of a governmental agency action or litigation), governmental or quasi-governmental requests, or a regulatory organization, or to relevant third parties such as site technicians, brokers, auditors, lawyers, or professional advisors. In the event that Digital First Media considers it necessary or where required by law to disclose Employee Information, we may share your Employee Information with our outside lawyers, law enforcement, or others who are legally authorized. As Digital First Media continues to develop our business, we may buy or sell assets. In the event that Digital First Media or substantially all of our assets are acquired, Employee Information may be one of the transferred assets.

Miscellaneous

Changes to this Policy. Digital First Media reserves the right to change or update this Policy, or any other of their policies or practices, at any time, and will notify users of this Platform by posting such changed or updated Policy on this page. Any changes or updates will be effective immediately upon posting to this Platform.

California Residents. If you are a resident of California, California Civil Code Section 1798.83 may permit you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. In addition, if you are under the age of 18 you may be entitled to request and obtain removal of Personal Information that you post on our Platform. To make such a request, please contact us by using the information in the “Contact Us” section.

Contact Us  
If you have any questions or comments regarding our privacy practices, you may contact us at privacy@digitalfirstmedia.com. Or through postal mail at: Attn: Legal, 4 North Second Street, Suite 800, San Jose, CA 95113

If Digital First Media needs, or is required, to contact you concerning any event that involves information about you we may do so by email, telephone, or mail.