Last modified: September 9, 2020
This Policy describes how we collect, use, share and secure the personal information we may collect when you visit the RMG Sites or that is otherwise disclosed or submitted to RMG. It also describes your choices regarding use, access, deletion, and correction of your personal information. We will review the notice regularly and publish updates as required by law, statute and/or regulation where your rights will be no less than what is required by law, statute, and/or regulation. BY USING THE RMG SITES OR SERVICES, YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION AS SET FORTH IN THIS PRIVACY STATEMENT OR AS OTHERWISE PERMITTED BY APPLICABLE LAW. YOU ALSO ACKNOWLEDGE THAT RMG MAY PERIODICALLY CHANGE, MODIFY, ADD OR REMOVE OR OTHERWISE UPDATE THIS PRIVACY STATEMENT AT ITS DISCRETION, WITHOUT PRIOR NOTIFICATION.
Please note that:
- All the information set out in this Policy may not apply to you. Our interactions with you, and the choices you make with regard to how you use the RMG Sites, products or services, will determine which portions of the Policy apply to you and your personal information. Wherever we provide examples of information in this Policy, the examples are not intended to be an exhaustive list;
- When you share personal information with us or when we collect personal information about you, we will use it in line with this Policy. Please read this Policy carefully. If you have questions or concerns about your personal information, please contact us at email@example.com; and
- This Policy does not cover our customers’ use of your personal information outside of the products and services we may provide them. We are not responsible for the privacy practices of our customers. Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by third parties. Any such participation will be subject to the relevant third party’s terms and conditions.
PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT
We may collect your information in several ways, including the following:
- Information You Provide Us Directly. We collect personally information which you choose to provide us directly.
- Information We Receive from Our Customers. We may collect information from our customers who provide your information to us so that you (for the benefit of the customer) are able to login to the RMG Sites and/or services.
- Information We May Receive from Other Parties. We may combine the information we receive from you with information we receive from other sources.
We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so under applicable law. The chart below summarizes when we collect personal information, the types of personal information we collect and how we use the personal information.
HOW WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES
- We share information with third parties for advertising purposes as described below under “Cookies and Similar Technologies”.
- We may share your information to provide the product or service you have requested.
- We may share your personal information with third party service providers or data processors that help manage our business and deliver services, for example, IT service providers who help manage our IT and back office systems or administer the RMG Sites and services. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
- We may share information with government organizations and agencies, law enforcement and regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
- We may share information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (1) detect, prevent or otherwise address fraud, security or technical issues, or (2) protect against harm to the rights, property or safety of RMG, its users or the public as required or permitted by law.
- We may share in aggregate, statistical form, non-personal information regarding the visitors to the RMG Sites with our partners, affiliates or advertisers.
- If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.
In addition to the above, we may share personal information about you with others to the extent you consent to such sharing.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
International data transfers
We may transfer to and store the personal information we collect in countries other than the country in which the personal information was originally collected, including countries outside the EU/EEA, in accordance with applicable law. Those countries may not have the same data protection laws as the country in which the personal information was provided. For example, your personal information may be stored in the United States and your personal information may be transferred to or accessed by RMG and its service providers in another country. When we transfer personal information to other countries, we will protect the personal information as described in this Policy and comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside the EU/EEA. This includes by entering into the European Commission’s EU Standard Contractual Clauses with the data importer, or ensuring that the data importer has certified to the EU-U.S. Privacy Shield Framework, or has implemented Binding Corporate Rules. To obtain a copy of the safeguards we have put in place, please contact us as indicated below. Please contact the Data Protection Officer (whose contact details are in the “Contact Us” heading below) for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
COOKIES AND SIMILAR TECHNOLOGIES
When you visit the RMG Sites or click on a banner advertisement, we and our partners, affiliates, or analytics or service providers may send one or more cookies or similar technologies to your computer or other device to collect information that helps us improve the quality of RMG Sites and service and the online experience of our visitors and users. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. The types of personal data we process in each of these contexts is further explained below:
- Cookies and other data collection technologies: We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on the RMG Sites into three categories, which you can manage:
- Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
- Performance cookies: These cookies collect information in an anonymous form about how visitors use the RMG Sites. They allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it and the approximate regions that they are visiting from. These are first party cookies.
- Functional cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. These are first party cookies.
- Targeting or advertising cookies: These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited the RMG Sites and may help us in compiling your profile. These cookies may be first or third party and are usually persistent meaning that they will be kept on your device until their expiration or earlier manual deletion.
- Social Media cookies: These cookies allow you to connect with social media networks such as Facebook, LinkedIn and Twitter. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. We may combine information from these types of cookies and technologies with information about you from any other source.
We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of the RMG Sites.
When you arrive on the RMG Sites a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘okay’. Once your consent has been provided, this message will not appear again when you revisit. If you prefer not to receive cookies while browsing the RMG Sites, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of the website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on the RMG Sites. You do not need to have cookies turned on, however, to use/navigate through many parts of the RMG Sites, except that access to certain of RMG’s web pages may require a login and password.
SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION
We are committed to earning and keeping your trust. We understand the need for your personal information to remain secure and private, and we have implemented security practices and procedures designed to safeguard your information.
Please remember that you also play a valuable part in data security. You should never share your account password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using the RMG Sites, you should log out of your Account and exit your browser so that no unauthorized persons can use the RMG Sites under your name or Account. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
RMG safeguards the security of the data you send us with physical, electronic, and managerial procedures. In certain areas of RMG Sites, RMG uses encryption to enhance the security of data transmissions. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a complex combination of letters and numbers, and make sure you use a secure browser.
We will retain your information for as long as your account is active or as needed to provide you services and to fulfill the purposes for which the data was collected. We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements.
How we use personal information to keep you up to date with our services
We may use personal information to let you know about our services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activities with you.
We also work with carefully selected third parties, such as promotional partners and others with whom we have marketing or other relationships. At all times, in accordance with your marketing preferences, these third parties may contact you by email, SMS/text, social media or through other communications channels to tell you about products and services that they believe would be of interest to you.
At any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communicate with you. You can ask us to stop direct marketing at any time by following the unsubscribe link you will find on all the email marketing messages we send you. Alternatively you can contact us at email@example.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email).
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences in your account with us. Further, if (in accordance with your marketing preferences) you receive marketing from the third parties referred to above, we recommend you review any relevant third party’s privacy notice for how they use your personal information.
Be aware that if you unsubscribe from our marketing communications we may be unable to notify you of services or offer to meet your needs. If you unsubscribe from marketing communications from us, you may still receive operational and service messages from us.
Please note that information you voluntarily include in bulletin boards, chat rooms and other online forums we may offer may be viewed and used by anyone with access to those forums. We are unable to control any use of such information by these third parties.
SOCIAL NETWORKING SITES
Integration with social networking sites may be present on the RMG Sites, and such integration is provided to enhance user experience. If you use any social networking service in connection with the RMG Sites and or access the RMG Sites through your other social networking account(s), RMG may collect relevant information necessary to enable the RMG Sites to access and collect your data contained within that particular social networking service (e.g., such as your Facebook profile information). Please remember, however, that the manner in which such third party social network provider uses, stores and discloses your information is governed solely by that provider’s policies, and RMG will have no liability or responsibility for the privacy practices or other actions of any third party site or provider that you may enable and link to your online experience with RMG.
COLLECTION OF INFORMATION FROM CHILDREN
None of the RMG Sites, products or services are intended for use or purchase by children. Accordingly, we do not knowingly collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13, please contact us at firstname.lastname@example.org.
INFORMATION FROM THIRD PARTIES AND THIRD PARTY LINKS
We may receive information about you from third party companies that specialize in collecting publicly available information. This may include estimated demographic information and information from public registers, such as the electoral register. We may link information about you that we collect from these third parties with other information that we collect about you.
The RMG Sites may contain links to other applications or websites that may not be owned or operated by RMG. We cannot control nor are responsible for the privacy practices or content of such other applications or websites. Credit card or other financial information submitted by you during the online purchase of products and services on the website are not visible, collected or stored by us, either on the website, or any other system managed by us. All credit card transactions are processed directly via a third-party payment processor, and at no point during the payment transaction is credit card or other financial information available to us. We encourage you to read the privacy statements of each application that you use and website that you visit.
ACCESS, DELETION, AND/OR CORRECTION OF YOUR PERSONAL INFORMATION
Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account and contacting us through our support channels or contacting us at email@example.com. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, verify your identify, or may need to retain your personal information in order to continue providing a service.
LEGAL RIGHTS AVAILABLE TO EU DATA SUBJECTS
Subject to applicable law, you have the right to request access to the personal information we maintain about you, rectification of your personal information if it is inaccurate or outdated, or erasure of your personal information in certain circumstances specified by applicable law. You may also request the restriction of the processing of your personal information or object to that processing on grounds relating to your particular situation. In addition, and subject to applicable law, you have the right to receive a copy of your personal information in a structured, commonly used, machine readable format, and, in some cases, may have the right to have that personal information transmitted to another organization.
You can exercise your rights by sending a request to firstname.lastname@example.org or to the mailing address referenced in the Contact Us section. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Our services collect information under the direction of our customers, and has no direct relationship with the individuals whose personal data it processes. If you are a customer or employee of one of our customers and would no longer like to be contacted by one of our customers that uses our service, please contact the client that you interact with directly.
RMG acknowledges that you have the right to access your personal information. RMG has no direct relationship with the individuals whose personal data it processes on our service platform. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the RMG’s customer (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
The primary point of contact for all issues arising from this Policy is our Data Protection Officer. Our Data Protection Officer can be contacted in the following ways:
Attn: RMG Privacy
RMG Networks Holding Corporation
15770 N. Dallas Parkway, Suite 1100
Dallas, TX 75248
If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority. For the EU, your local authority can be found here.
FOR CALIFORNIA CONSUMERS
Notice of Collection and Use of Personal Information
As described elsewhere in the Policy in more detail, we may collect, and may have collected during the past 12 months, the following categories of personal information about you:
- Identifiers: including real name, postal address, unique personal identifier (such as cookies, mobile ad identifiers and similar technology), internet protocol address, email address, account name, and other similar identifiers
- Protected Classifications: characteristics of protected classifications under California or federal law
- Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Employment Information: professional or employment-related information
- Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Additional Data Subject to Cal. Civ. Code § 1798.80: such as physical characteristics or description, education, bank account number, credit card number, debit card number, and other financial information
- Inferences: inferences drawn from any of the information identified above
We may use, and may have used during the previous 12 months, these categories of personal information for the purposes described in our Policy (under the heading “Personal Information We May Collect And How We May Use It”), including for the business purposes that are specified in the CCPA.
Sharing/Sale of Personal Information
You have the right to opt out of these disclosures of your information, as detailed below.
We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request. To submit an access or deletion request, or to opt-out of the sale of your personal information, please either email us at email@example.com or mail us at the address provided in our Policy under the heading “Contact Us”.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we will verify your identity by requiring you to sign in to your account and/or answer security questions related to your account. If you do not have an account with us, or an email address on file with us (such as if you signed up to receive our marketing emails), then there may not be a reasonable method by which we can verify your identity to the level of certainty required by the CCPA. This is because historically we have not linked device identifiers or advertising IDs to named actual persons. Accordingly, if you do not have an account with us, or an email address on file, and you request access to or deletion of your personal information, we will not be able to process your request at this time. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, then (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This section is available in alternative formats upon request. To request it in an alternative format, please either email us at firstname.lastname@example.org or mail us at the address provided in our Policy under the heading “Contact Us”.