privacy statement was amended as of May 3rd, 2020 and is effective as of that
date. The English language version of this privacy statement is the controlling
version regardless of any translation you may attempt.
NAVIGATING THROUGH THIS STATEMENT
You can use the links below to
navigate to areas of this statement that apply specifically to you, or which
may otherwise be of interest:
Some Important Vocabulary
What Personal Information Do
How Do We Use the Personal
Information We Collect?
Whom Do We Share Personal Information?
How Do We Protect Collected
Your Rights And
This Privacy Statement
SOME IMPORTANT VOCABULARY
Although not itself a contract, this
privacy statement is an important document that explains how we address some of
our legal obligations, and your related legal rights, involving personal
information. Clarity is, therefore, important. We'll use this section to let
you know about some words that have special meanings whenever you see them in
this statement. Let's start with the word statement
itself: when we reference this
statement, this privacy statement
and our statement, we mean the
Privacy and Data Security Statement you are reading now. Wherever we say Company, we, us, or our, we mean Company Legal Name. We
use the words you and your to mean
you, the reader, and other visitors to our online and mobile resources who are,
in all cases, over the age of 18. This age requirement is discussed in more
detail later in this statement here. We
also want to be very clear about exactly what parts of the Company corporate
enterprise are covered by, and adhere to the policies and procedures explained
in this statement.
When we talk about our online
and mobile resources, we mean all websites, portals or other features we
operate to allow you to interact with us and our systems, as well as the mobile
apps we've created and distributed to let you interact with the content we
provide. An affinity action is when you follow us, like us or take a
similar or analogous action on our external social media presence.
Finally, and perhaps most
importantly, when we refer to personal
information, we mean information that
can be used to identify or easily be linked to you. The privacy laws in some
jurisdictions include unique elements in what they consider to be the personal
information of the data subjects they protect.
PERSONAL INFORMATION DO WE COLLECT?
We collect personal information from four groups of data
to, and users of, our online and mobile resources
members of our workforce and those who apply for posted jobs
third party vendors and business partners
The categories of information we
collect from each of these groups differs. As you may have noticed, it's
possible that the same person could fall into more than one group. For
instance, someone who is a customer might also work for one of our vendors. Or someone
who works for us might, on their day off, visit one of our general websites. We
explain below the different categories of personal information we collect from
each group of data subject.
Visitors and Users of our Online and
If you visit and/or use our online
and mobile resources, we collect and retain a very limited amount of personal
information through automated/technical means. We describe that automatic
collection here. In addition to that, if you choose to participate in, or
make use of certain activities and features available via our online and mobile
resources, you will need to provide us with information about yourself. We
describe that type of voluntary submission immediately below. By using our online and mobile resources,
you are signifying to us that you agree with this section of our privacy
statement and that we may use and disclose your information as described.
Voluntarily Submitted Information.
Here are some of the ways you
voluntarily give us your personal information. The types of personal
information you will be submitting to us in these situations is almost always
limited to identifiers such as your
name, email address, mailing address and phone number. You can read about how
we use that personal information here.
Emails and Texts If you choose to send us an email from our contact us link
or a similar link, you will be giving us your email address and any other
personal information that may be in your message or attached to it. The same is
true if you send us a text message.
Creating Accounts; Signing up for
Newsletters If we make an account creation
feature available to the general public (that is, to visitors/users who are not
our customers or workforce members) you will be giving us at least your email
address and potentially other identifiers. The same is true if you sign up to
receive a newsletter or other informational or marketing material we publish.
Registering for Events When you register for events, conferences or programs we
ourselves may host (rather than outsource to a third party
event manager with its own privacy policies), you will be submitting the types
of identifiers described above. If the event requires a fee, we may also ask
you to submit credit card or other
Social Media and Community Features
Some of our online and mobile resources may offer social media-like
community features letting users post or upload messages, comments, and/or
image or other files and materials. If you choose to make use of these features
the information you post, including your screen name and any other personal
information, will be in the public domain and not covered/protected by this statement.
Customer Portals and Job Applicants
Some of our online and mobile
resources are used to help us serve our customers and allow candidates to apply
for available jobs. We discuss personal information submitted in those
situations elsewhere in this statement such as here and here.
If you prefer we not receive the
above-described personal information, please don't submit it. This means you shouldn't participate
in the applicable activities on, or use the applicable features available from
our online and mobile resources. Such participation and use is
strictly your choice. By not participating, you may limit your ability to take
full advantage of the online and mobile resources, but most of the content in
our online and mobile resources will still be available to you.
Automatically Collected Information.
When you visit or use our online and
mobile resources, basic information
about your internet/electronic activity is automatically collected through
your browser via tracking technologies, such as cookies. As just about
everyone knows by now, cookies are small text files downloaded onto your
computer or mobile device. Cookies allow us to collect your IP address and recognize your computer
or mobile device and store some information about your preferences for using
our online and mobile resources or past actions, such as:
type of browser and operating system you use
date and time and length of your visit
pages visited, graphics viewed and any documents downloaded
to other sites you accessed from our online and mobile resources or used to
navigate to our online and mobile resources
Additional information about cookies
and tracking technologies is available here.
If you access our online and mobile
resources from a phone or other mobile device, the mobile services provider may
transmit to us certain information such as uniquely identifiable mobile device
information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device
identification information. Some mobile phone service providers also
operate systems that pinpoint the physical location of devices and we may
receive this geolocation data as
Finally, when you use our online and
mobile resources, we may allow third party service providers to place their own
cookies or similar technologies in order to engage in the same types of
collection we describe above. For example, some Company companies covered by
this statement use third party web analytics services such as those offered
by Google Analytics. For more information on how Google specifically uses this
data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt
out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
User Beware: External Sites, Apps, Links and Social Media.
Some Company companies maintain a
presence on one or more external social media platforms such as Twitter,
Facebook, YouTube and LinkedIn. We may further allow the community features of our
online and mobile resources to
connect with, or be viewable from, that external social media presence.
Similarly, our online and mobile resources may contain links to other websites
or apps controlled by third parties.
We are not responsible for either
the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps,
sites and platforms are not controlled by us and therefore have their own
our online and mobile resources apply to our social media presence or any third party sites or apps to which we may link. That
means even if you take an affinity action on our specific social media presence, and identifiers
about you are automatically collected and given to us as a result, that
collection and transfer is governed by the privacy policies and other terms of
the applicable social media platform and are not our responsibility. If you
have questions about how those apps, sites and platforms collect and use
personal information, you should carefully read their privacy policies and
contact them using the information they provide.
Personal Information we collect from
We necessarily collect a lot more
personal information from our customers and those who apply to be customers
than we do from others.
Customers enter into a contract with
us. That contract is separate from this statement and has its own terms and
conditions for notice of collection and governing our overall confidentiality,
data privacy and data security obligations. As a result, those terms, and not
this statement, apply to the personal information of customers.
For those who apply to become
customers, we provide notice of what personal information we collect on the
proprietary documents that are part of our application process, or the apps and
portals we operate for such purpose, doing so via confidential Company terms
and conditions published thereon. In some cases, customer applicant data will
be collected by one of our business partners and shared with us. In those
situations, the legal responsibility to provide notice rests with that business
partner, not Company.
Personal Information we collect from
our Workforce and Job Applicants
We collect and retain the types of professional or employment related personal
information you would expect a U.S. employer to have about its U.S.
workforce such as name, age, home address, and personal information for
payroll, tax and benefits. When the law allows or requires (such as for
compliance with equal opportunity/non-discrimination laws) we may also collect characteristics of protected
classifications such as race, gender, and ethnicity. Similarly, when
someone applies for an open job position, including via portals or other online
and mobile resources, we collect the personal information we need, and which
the law allows, to evaluate their applications.
We provide notice of what personal
information we collect from our workforce/applicants in our confidential human
resources manuals and other documentation, or on the proprietary apps and portals
we operate for such purpose doing so via confidential Company terms and
conditions published thereon. In some cases, portals and apps may be operated
by third parties who transfer the personal information to us. In those
situations, the legal responsibility to provide notice usually rests with the
third party, not Company. You can read about how we use the personal
information we collect from our workforce and job applicants here.
Personal Information we collect from
Vendors and Business Partners
Like all large corporate enterprises, we buy goods and
services, lease equipment and office space and attend industry events. In doing
so, we interact with many existing and potential vendors and business partners
from whom we necessarily collect certain personal information in connection
with our contractual and business relationships. Typically, the categories of
personal information collected in those cases will be limited to what is often
referred to as minimum business contact
information such as name, business title, business address and business
email. As a result, if legally required, we make a reasonable effort to provide
notice at the point of collection, or address the question of notice in the
applicable business contract.
HOW DO WE USE THE PERSONAL
INFORMATION WE COLLECT?
We use personal information we
collect only in the manner and through the means allowed by applicable law.
That means we determine whether we have a lawful basis/legitimate business
purpose to use your personal information before doing so. As stated in
applicable law, such lawful bases/legitimate business purposes include
receiving express consent, operating our business, performing a contract, and
complying with a legal obligation. More specifically, we use the personal
information of each
group of data subjects as follows:
Visitors and Users of our Online and
We use the automatically collected
personal information described here to
compile generic reports about popular pages/features of our online and mobile
resources, and to see how users are accessing our online and mobile resources
and in some cases (such as affinity actions) send materials to you. We use the personal information you
voluntarily submitted, as described here, to
respond back directly to you and/or send you the information you requested or
about which you inquired. We also may use any such personal information you
provide to customize our programs and newsletters to make them more relevant to
you. We do not sell or rent personal
information automatically collected by, or which you voluntarily provide when
using our online and mobile resources.
We use personal information
collected from our customers to administer their policies and process their
claims. As mentioned above, customers enter into confidential contracts with us
and those contracts have their own terms and conditions describing the manner
and means of our use of customer personal information. As a result, those terms
and not this statement, apply to our use of the personal information of
customers. We use personal information collected from customer applicants to
evaluate their applications and underwrite and provide premium quotes. We
provide notice of our scope of use via confidential Company documents or by
publication on the proprietary apps and portals we operate for such purpose.
Our Workforce and Job Applicants
We use personal information
collected from our workforce to operate our business, perform our duties as an
employer, and fulfill our commitments to workforce members (such as benefits
administration). We use personal information collected from job applicants to
evaluate their candidacy and process their applications. We describe our use of
workforce and job applicant personal information in greater detail in
confidential Company human resource policy documents or by publishing such
policies on the proprietary workforce/applicant portals and apps we operate.
Vendors and Business Partners
We use the personal information collected from our vendors
and business partners (which, again, is largely minimum business contact
information) to manage, administer and perform under our contracts with them,
or share information about our products. We also may from time-to-time use
personal information about their individual personnel to perform background
checks on those who are provided access to our facilities or technology
networks so that we can help protect the personal information of others stored thereon.
We describe our use of vendor and business partner personal information in
greater detail in our confidential contracts with those parties.
WHOM DO WE SHARE PERSONAL INFORMATION?
We may share your personal
information as described below. This sharing applies to the personal
information of all four groups of data subjects described here.
We may share personal information to
other companies within Company who will use such information in the same way as
we can under this statement.
We may disclose personal information
to government authorities, and to other third parties when compelled to do so
by such government authorities, or at our discretion or otherwise as required
or permitted by law, including responding to court orders and subpoenas.
To Prevent Harm
We also may disclose such
information when we have reason to believe that someone is causing injury to or
interference with our rights or property, or harming or potentially harming
other persons or property.
If Company or any of the companies
covered by this statement, or any of their affiliates or subsidiaries, sell or
transfer all or substantially all of their assets, equity interests or
securities, or are acquired by one or more third parties as a result of an
acquisition, merger, sale, reorganization, divestiture, consolidation, or
liquidation, personal information may be one of the transferred assets.
Vendors and Business Partners
We also share personal information
with those of our vendors and business partners who need it to perform under
the contracts we have with them. As part of our Security Program, we have adopted standards for those vendors and business
partners who receive personal information from us. We attempt to bind such
vendors and business partners to those standards via written contracts. Such
standards include expectations that when we share personal information with our
vendors and business partners, they will comply with all applicable privacy and
data security laws and regulations and our Security Program, and will
contractually require and cause their subcontractors and agents to do the same.
We further attempt to contractually restrict what our vendors and business partners
can do with the personal information we provide to them such that it:
used only to the minimum extent necessary to carry out the business purpose for
which it was provided
not disclosed to anyone else without our consent or under our instruction
as between us and the applicable vendor or business partner, our property
not transferred out of the United States without our consent
For any personal information our vendors and business
partners process or store at their own locations, we further expect them to use
technology infrastructure meeting, at least at the facilities level, minimum
recognized standards for security controls. Such recognized standards include those published by the
International Standards Organization, the National Institute of Standards and
Technology the AT 101 standards (for data security matters) published by the
American Institute of Certified Public Accountants, the Payment Card Industry
Security Standards Council, or any reasonably equivalent standards.
Please note, however, that we cannot guarantee that all of
our vendors and business partners will agree to the above-described contractual
requirements; nor can we ensure that, even when they do agree, they will always
HOW DO WE PROTECT COLLECTED PERSONAL
Our Data Security Program
We have adopted, implemented and maintain an enterprise-wide
corporate information security and privacy program that includes technical,
organizational, administrative, and other security measures designed to
protect, as required by applicable law (including all those described above),
against reasonably anticipated or actual threats to the security of your
personal information (the Security
Program). Our Security Program was created by reference to widely
recognized industry standards such as those published by the International
Standards Organization, National Institute of Standards and Technology and the
Payment Card Industry Security Standards Council. It includes, among many other
things, procedures for assessing the need for, and as appropriate, either
employing encryption and multi-factor authentication or using equivalent
compensating controls. We therefore have every reason to believe our Security
Program is reasonable and appropriate for our business and the nature of
foreseeable risks to the personal information we collect. We further
periodically review and update our Security Program, including as required by
Our Incident Response and Management Plan
Despite the significant investment
weve made in, and our commitment to, the Security Program including
enforcement of our third party oversight procedures, we cannot guarantee that your personal information, whether
during transmission or while stored on our systems, otherwise in our care, or
the care of our vendors and business partners, will be free from either failed
or successful attempts at unauthorized access or that loss or destruction will
never occur. Except for our duty to maintain the Security Program under
applicable law, we therefore necessarily disclaim, to the maximum extent the
law allows, any other liability for any such theft or loss of, unauthorized
access or damage to, or interception of any data or communications including
All that said, as part of our Security Program, we have
specific incident response and management procedures that are activated
whenever we become aware that your personal information was likely to have been
compromised. Those procedures include mechanisms to provide, when circumstances
and/or our legal obligations warrant, notice to all affected data subjects
within the timeframes required by law, as well as to give them such other
mitigation and protection services (such as the credit monitoring and ID theft
insurance) as may be required by applicable law. We further require, as part of
our vendor and business partner oversight procedures, that such parties notify
us immediately if they have any reason to believe that an incident adversely
affecting personal information we provided to them has occurred.
YOUR RIGHTS AND OPTIONS
If we are using your personal
information to send you marketing materials, such as newsletters or product
alerts via text or email, you may opt out by following the opt-out instructions
in the email or other communication (e.g., by responding to the text with
STOP). In addition, certain of our online and mobile resources will provide a
centralized opt-out link allowing you to opt out of any programs in which you
may have enrolled using that particular online or mobile resource. When we
receive your request, we will take reasonable steps to remove your name from
our distribution lists, but it may take time to do so. You may still receive
materials for a period of time after you opt out. In addition to opting out,
you have the ability to access, amend and delete your personal information by
contacting us using the contact information below. Opting out of or changing
affinity actions or other submissions or requests made on our third party social media platform, will likely require that
you do so directly on that platform as we do not control their procedures.
Some browsers have a do not track
feature that lets you tell websites that you do not want to have your online
activities tracked. At this time, we do not specifically respond to browser do
not track signals.
Federal law imposes special
restrictions and obligations on commercial website operators who direct their
operations toward, and collect and use information from children under the age
of 13. We take those age-related requirements very seriously, and, consistent
with them, do not intend for our online and mobile resources to be used by
children under the age of 18, and certainly not by anyone under the age of 13.
Moreover, we do not knowingly collect personal information from minors under
the age of 18. If we become aware that anyone under the age of 18 has submitted
personal information to us via our online and mobile resources, we will delete
that information and not use it for any purpose whatsoever. We encourage
parents and legal guardians to talk with their children about the potential
risks of providing personal information over the Internet.
TO THIS PRIVACY STATEMENT
We reserve the right to change or
update this statement from time to time. Please check our online and mobile
resources periodically for such changes since all information collected is
subject to the statement in place at that time. Typically, we will indicate the
effective/amendment date at the beginning of this statement. If we feel it is
appropriate, or if the law requires, well also provide a summary of changes
weve made near the end of the new statement.
If you have questions about our
privacy statement or privacy practices, please contact Our Privacy Office:
Nano Media Inc.
PO Box 3540
Silver Springs, NV 89429