Updated October 25, 2020
When you use or interact with a U.S. website, mobile app (each considered a “Digital Service”) operated or owned by The Influence Times, we and third parties may obtain certain information about you. Please carefully review our full Privacy Notice mentioned below for a detailed explanation of our practices.
B. WHAT INFORMATION WE COLLECT
When you use our Digital Service, we may collect different types of information related to you and your use of the Digital Service. This may include information such as your name, address, or contact information (this type of information may be called “personal information” or “personally identifiable information”). The information we obtain generally consists of information you give us about yourself, information you give us about others, information automatically collected about your interactions with our content or ads on third-party websites, apps or other media, and information we get from other sources.
1. Information that you give us
The information you give us may include details such as:
- Contact information (e.g., name, mailing address, email address or phone number and/or mobile number).
- Information regarding to Demographic, interests and other household information (e.g., age, gender or education).
- Any Information you provide when you choose to participate in our survey, contest or similar initiative.
- Information regarding your precise location associated with your device when location services are active. To prevent the collection of precise location information you will need to refer to instructions provided by your mobile service provider or device manufacturer.
- Other information you may allow us to access through your device’s permissions settings, such as your contacts or address book.
- Transactional and activity information (e.g., requests or searches).
2. Information you give us about others
3. Information automatically collected
Automatically certain information is logged in about visits to the Digital Services, such as the number of visitors, which browsers and devices are used to access the Digital Services, and information about other technical issues. In addition, automated means may be used by us and some third parties to collect certain information about your activities over time across the Digital Services as well as across third-party sites, or other media. The tools that collect this information vary and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits (“SDKs”). These technologies may be included in our web pages, mobile apps, emails, and other digital content. The tools may assign or collect unique cookie IDs or other identifiers associated with your browser and/or device. This collection of information may happen while you are using a Digital Service or while the Digital Service is running in the background of your device.
The information automatically collected may include:
- Information about your computer, device, browser and operating system (e.g., type, model, or version).
- Internet protocol (IP) address, which may be used to derive your general geographic area (e.g., city and country).
- Information about how you interact with the Digital Services, including browsing activities and data that reflect the content you have accessed, clicked on, or viewed.
- Information like your Demographic, your interests and household information.
- Information about how you interact with email messages and other methods of communications, such as whether you opened the email or forwarded the email or clicked on links present in the email.
4. Information we obtain from other sources
We also receive information about you from other sources. For example, we may obtain data from:
- Information from third-party data suppliers such as data aggregators, public databases and business partners. They may provide us with information regarding demographic and other information that helps us learn about our users of the Digital Services.
- Information from Social Media Platforms. When you engage with our content or ads on Social Media Platforms, or interact with features on the Digital Services that contain content or features provided by Social Media Platforms (e.g., tools that allow you to share our content with others on Social Media Platforms), we may obtain information from Social Media Platforms, including your username, user ID, demographic information and other information, all subject to the settings and privacy practices of the relevant Social Media Platform.
C. HOW WE USE THIS INFORMATION WE OBTAIN
User Information is used to provide Services to you by The Influence Times and its partners, which includes using such information to:
- To provide you with the Digital Services. This includes:
- Processing your requests regarding the Digital Services and products or services, or your participation in a survey, sweepstakes, contest, promotion, event or similar initiative.
- By Maintaining, operating, improving and developing the Digital Services and all related content, services, including developing new features based on users’ interactions with the Digital Services.
- By learning about our users of the Digital Services and analyzing how our users interact with and respond to the Digital Services This includes measuring usage, optimizing usage, reliability and better performance, conducting market research and analyzing trends.
- To communicate with our users. This includes:
- Sending you messages that contain information about the Digital Services (e.g., to confirm subscription or notify of changes to a Digital Service).
- Sending marketing or promotional communications, which includes offers and / or promotions about our or third parties’ products and services.
- Replying to your questions or addressing your requests.
- Communicating about surveys, sweepstakes, contests and promotions.
- For advertising and marketing purposes, including interest-based advertising. This includes:
- Developing, analyzing, managing and conducting advertising and marketing campaigns, promotions and offers, related to our content, products and services or third parties’ products and services.
- Interest-based targeted or personalized advertising based on your interests as derived from your activities over time on the Digital Services and online services operated by third parties, as well as information from other many other sources, including information collected offline. These ads may consist of text ads, images, animations or videos and will be displayed to you based on various factors, such as the context of the site or app in which they appear (e.g., fashion, fitness section), information you provided when you created an account, your activities on the site or app (e.g., what pages were viewed, searches that were performed or ads that were clicked), and also based on your information such as your demographic, interests and household information.
- We and third parties may use automated means to collect information on the Digital Services and on third-party sites, apps or other media to (a) collect information for interest-based advertising purposes or (b) serve you interest-based ads. These automated means will vary depending on the Digital Services and will include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and SDKs. These technologies may use unique identifiers associated with your browser or device to support interest-based advertising.
- For Interest-based advertising purposes we may use online and offline information we obtain about you, which includes your personal information. We may aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.
- These interest-based ads may be displayed to you by third parties, such as ad networks or exchanges.
- There are steps you can take to limit the collection of your information for interest-based advertising purposes. These steps vary for the web and mobile app environments and are browser and device specific.
- In serving these interest-based ads, we adhere to the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance.
- Analyzing, developing and measuring the performance, effectiveness, and reach of our advertising (including interest-based ads) and marketing efforts on the Digital Services and elsewhere.
- To protect our rights or the rights of others. This includes:
- Performing assessments and testing or troubleshooting activities.
- Properly backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Digital Services.
- Complying with and enforcing applicable industry and legal requirements (including legal process such as court orders, warrants or subpoenas) and fulfilling contractual obligations.
D. HOW WE SHARE THIS INFORMATION
We may share the information we collect with:
- Affiliates and Subsidiaries. We work very closely with affiliates and their subsidiaries within the The Influence Times family with whom we share your information as necessary or appropriate to operate the Digital Services.
- Service Providers. Related to the operation and provision of the Digital Services, we use various third parties to provide services such as email distribution, cloud computing, analytics, digital content performance measurement, ad serving and managing promotions or events. To perform these services our service providers use the information we provide to them as necessary or appropriate.
- Advertising and Marketing Related Service Providers. We may need to provide your information to advertisers, advertising agencies, ad networks, ad exchanges and other entities that help in creating, delivering and assessing advertising or marketing campaigns, including interest-based ads.
- Content Measurement Companies. We may include third-party measuring software in the Digital Services to enable market research or to measure the digital content and video content consumption.
- Interactions with Social Media Platforms. Relevant social media platforms may collect information if you interact with social media widgets, share content using social media share buttons, or access features of the Digital Services that contain content or features provided by Social Media Platforms. You should review the privacy policies of the Social Media Platforms that you engage with as we are not responsible for their privacy practices.
- Business Partners. Your information may be provided to business partners including, without limitation, joint marketing partners and content sponsors, for various purposes. For example, we may partner with a third party to offer products on a co-branded, co-sponsored or cross-promotional basis that involves the sharing of information. These initiatives may be offered on any of the Digital Services or on any other media.
- Other Parties When Required by Law or As Necessary to Protect Our Rights. Your information may be shared as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Digital Services or other individuals and entities, or to comply with or enforce applicable industry standards, law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.
- Corporate Transactions. We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.
- With Your Consent or at Your Direction. In addition, we may share your information with third parties when you consent to or request such sharing.
E. YOURS CHOICES, INCLUDING MARKETING AND INTEREST-BASED ADS OPT-OUTS
Direct Marketing Opt-Outs
- Email marketing. By clicking on the “unsubscribe” link contained in the emails you may opt out of receiving marketing or promotional emails from us. Please keep in mind that you may still receive transactional emails or other communications related to the use of Digital Services even if you have opted out of receiving marketing or promotional emails (e.g., to inform you of changes to a Digital Service or in response to your password recovery request).
- Text message marketing. If you choose to participate in a text message marketing campaign or promotion offered in connection with a Digital Service, you may opt out of receiving marketing texts from us by following the instructions contained in those messages (e.g., texting the word STOP) or provided to you when you elected to receive text message marketing.
- Marketing by Third Parties. We may provide your contact information to third parties for their own marketing purposes. To request that third parties do not use your postal mailing contact information for their own marketing purposes (if we have your postal address), you may notify us through email at firstname.lastname@example.org.. Please indicate in your correspondence the name of the Digital Service or publication to which your request applies. In addition, you may be able to request that third parties do not use your email address (if we have it) for their own marketing purposes by logging into your account or the preferences center (if available) for the relevant Digital Service and adjusting your email preferences.
- Co-Branded, Co-Sponsored or Cross-Promotional Offerings. If you choose to participate in a co-branded, co-sponsored or cross-promotional offering, the brand, sponsor or other third party involved in that offering may use your information for its own purposes, including advertising and marketing purposes. You must contact the relevant third party directly to exercise your opt out choices with respect to such party’s use of your information.
Interest-Based Ads Opt-Outs
The steps are mentioned below that you can take to limit tracking of your activities and the delivery of interest-based ads in browsers and mobile apps you use to access the Digital Services. Please keep in mind that you will still see ads even if you opt out of interest-based ads, but these ads will not be based on your interests. In addition, if you take the steps described below, some automated means may still be used to collect information about your interactions with the Digital Services for the other purposes described in this Privacy Notice (e.g., to remember user preferences or enable specific functionality).
Please remember that opt-outs are browser-specific and device-specific. The technologies used to deliver the ads on websites and on mobile apps differ.
Website (Browser) Opt-Out
- Disabling Cookies. Many browsers will accept cookies by default. You may be able to change the settings to have your browser notify you before accepting cookies or refuse certain cookies.
- Opt-out Cookies. You can place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser.
- If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt-out choices for that specific browser.
- The opt-out mechanisms offered by the DAA and NAI are provided by third parties.
- The Influence Times does not control or operate these mechanisms or the choices provided through these mechanisms.
Mobile App Opt-Out
- Device Settings. You can adjust the settings provided by your device manufacturer to limit interest-based advertising on your mobile device, (eg., “Limit Ad Tracking” for iOS or “Opt-out of interest-based ads ” for Android)..
Please keep in mind that additional opt-out mechanisms or privacy settings may become available to you as the mobile environment continues to evolve. We encourage you to look into and review the information on opt-outs and settings that device manufacturers, technology companies and industry associations make available to you.
Do Not Track
The Influence Times does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.
- User account. If you have created an account with us, you may be able to review some of your information for that account by logging in and updating your information or user preferences.
- Device Settings. You may be able to review and adjust your preferences by updating the settings on your device (e.g., permitting us to collect precise location information).
F. HOW WE PROTECT YOUR INFORMATION
We use a variety of procedure and security technologies to help protect information from unauthorized access, use or disclosure. However, there is no method of transmission over the internet, or method of electronic storage that is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
G. NON-U.S. VISITORS
We operate and maintain the Digital Services from the United States. Any information that we obtain about you in connection with your use of the Digital Services may be processed and stored in the United States or other countries.
H. CHILDREN’S PRIVACY RIGHTS
This Digital Services are not intended for use by children, especially those under the age of 13, and we do not knowingly collect personal information from children under the age of 13.
I. LINKS TO THIRD-PARTY WEBSITES, MOBILE APPS OR OTHER SERVICES
The Digital Services may contain links to websites, mobile apps or other services operated by companies not affiliated with The Influence Times. In addition, the Digital Services may be made available to you through third-party platforms (such as app stores or Social Media Platforms) or other channels. We are not responsible for the privacy practices of any non-The Influence Times operated websites, mobile apps or other services and channels, and we encourage you to review the privacy policies or notices published by relevant third parties.
K. CONTACT US
If you have any questions about this Privacy Notice, please contact us by email at email@example.com. For questions related to your California Consumer Privacy Act of 2018 (CCPA) rights, please contact us by email at firstname.lastname@example.org.
L. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Your California Consumer Privacy Act of 2018 (CCPA) Privacy Rights
Residents of California may have the following rights:
- Right to know and access your personal information. Under CCPA, you have the right to:
- Know the categories of personal information we collect and the categories of sources from which we got the information;
- Know the business or commercial purposes for which we collect and share personal information;
- Know the categories of third parties and other entities with whom we share personal information; and
- Access the specific pieces of personal information we have collected about you. To do so, please email us at email@example.com and include your name, email address and your California postal address.
- Right to deletion. In some circumstances, you may ask us to delete your personal information. To do so, please email us at firstname.lastname@example.org and include your name, email address and your California postal address.
- Right to opt out of sales. We may share your personal information with third parties in ways that may constitute as a “sale” under CCPA. You may request that we do not “sell” your personal information on a going forward basis. If you wish to do so, please email us at email@example.com and include your name, email address and your California postal address. If you reengage with us after opting out of the “sale” of your personal information, such as signing up for a newsletter and/or entering a sweepstakes or contest your personal information will be collected and used in accordance with this Privacy Notice.
- Right to be free from discrimination. You may exercise any of the above rights without fear of being discriminated against.
You may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide including information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.
We will use the information you provide to make your CCPA rights requests to verify your identity, identify the personal information we may hold about you and act upon your request. We recommend that you submit the email and postal address that you used when you created accounts or signed up for a newsletter. After you submit a CCPA rights requests using one of our forms, you will be required to verify access to the email address you submitted. You will receive an email with a follow-up link to complete your email verification process. You are required to verify your email in order for us to proceed with your CCPA rights requests. Please check your spam or junk folder in case you can’t see the verification email in your inbox. If you are a California resident and have any questions regarding your CCPA rights under this Privacy Notice, please contact us at firstname.lastname@example.org.
We do not knowingly collect or disclose personal information of minors under the age of 16, without affirmative authorization.
Minors’ Right to Request Deletion of User-Posted Comments
You may request deletion if you are a California resident and registered user and posted comments, content or other information on the site or app when you were under 18 years old, by contacting us at email@example.com and indicate in the subject line “California take-down request.” You must provide us with the live URL where the content resides, a copy of the content you would like deleted (cut and pasted into your email), the date of publication, and – if applicable – the username associated with it. We will remove the posting (except as permitted or required by law). Note that our deletion does not ensure complete or comprehensive removal of your content from the internet and comments that may have been posted by others about you or your posting will remain accessible online.
Your Shine the Light California Rights (CA Civil Code § 1798.83)
You may also have the right to request a list of third parties to which certain personal information (as defined by California Civil Code § 1798.83) obtained through a Digital Service was disclosed by The Influence Times during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at firstname.lastname@example.org. For such a request, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name and complete postal address. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. Please also indicate in your request the name of the Digital Service to which your request applies. Please note that we will not accept requests via the telephone, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
O. ADDITIONAL INFORMATION FOR EUROPEAN VISITORS
The Influence Times provides the following additional information for Europe-based visitors to The Influence Times U.S. Digital Services in order to address our legal obligations in Europe (including the UK),
Who is Responsible for Your Information?
The data controller will be The Influence Times if you use or interact with a The Influence Times U.S. Digital Service. You can see the contact details in the “Contact Us” section above.
Legal Bases for Using Your Information
We process personal information for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases:
To perform our contractual obligations to you. We and our service providers process your information to perform our contractual obligations to you when we use your information to provide you with the Digital Services and related content, products or services and to communicate with you. We also send you informational communications on this basis, including to confirm a subscription or to notify you of a change to a Digital Service. Failure to provide requested information could prevent or delay the fulfilment of our contractual obligations.
- To pursue our legitimate interests. We process your information to meet our legitimate interests when we use your information to provide you with the Digital Services and related content, products or services, to communicate with you and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Digital Services and related content, products or services, and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries, service providers and business partners (including for our advertising and marketing purposes) and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.
- With your consent. We obtain your consent to process your information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the “Contact Us” section above.
Your Rights Over Your Information
In certain circumstances, you have a right to access or object to the use of personal information held about you (including in relation to direct marketing). You can also ask us to rectify, update, erase, restrict or to share your information in a usable format with another company. Such requests are subject to applicable law.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
If you would like to discuss or exercise such rights, please contact us at email@example.com. We will contact you if we need additional information from you in order to honor your requests.
Storing Your Information
Your personal information will be kept with us for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us:
- To maintain business records for analysis.
- To understand the market trends and/or audit purposes and to improve the Digital Services.
- To comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
- To defend, establish, exercise or bring any existing or potential legal claims.
- To carry out fraud detection and prevention.
- To deal with any complaints regarding our products and services.
Your information will be deleted when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
International Data Transfers
Information collected through the Digital Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. If we transfer personal data from the European Economic Area, United Kingdom and Switzerland we put in place safeguards. In particular, such safeguards include Privacy Shield Principles or European Commission-approved standard contractual clauses. For more information on these safeguards, please contact us at the details provided in the “Contact Us” section above.
Changes to the Privacy Notice
Where changes to this Privacy Notice have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you advanced notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
Privacy Officer and Complaints
Our Privacy Officer can be contacted at firstname.lastname@example.org
In the event you have a complaint or concern about privacy, we are committed to working with you to obtain a fair resolution. You have the right to make a complaint to a data protection authority If, you believe that we have not been able to assist with your complaint or concern.