This Policy was last updated on 5/19/2022.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE.
INTRODUCTION
Wright’s Media, Inc. (“Wright’s Media” also referred to as “we,” “us,” and “our”) respects the sensitive nature of the personal information you provide to us. We are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. We have created this Policy, and any documents referenced therein, in order to demonstrate our commitment to the privacy of those who visit our website, wrightsmedia.com (the “Site”), and use our services.
When does this Policy apply? This Policy describes our online information collection, storage and disclosure practices and the choices you have regarding how your personal information is collected and used by us. By accessing and using the Site or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use and disclosure of information described in this Policy. This Policy only governs the Site and our platform, and it does not govern off-line data collection.
Residents of the EU/EEA. Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the “EEA Residents” and “International Data Transfers” sections of this Policy for more information about provisions that may apply to them.
Residents of Brazil. Residents of Brazil should consult the “Residents of Brazil” and “International Data Transfers” sections of this Policy for more information about provisions that may apply to them.
Residents of Australia. Residents of Australia should consult the “Residents of Australia” and “International Data Transfers” sections of this Policy for more information about provisions that may apply to them.
HOW DO WE COLLECT AND USE PERSONAL INFORMATION?
Personal Information for which Wright’s Media is the Controller. If you are a user in the EU or EEA, for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), or if you are a user in Brazil, for the purposes of the Brazilian General Data Protection Law (the “LGPD”), we act as a data controller with respect to the personal information described below. In this role, we are responsible for implementing the applicable data protection principles and for safeguarding personal information. As a data controller, Wright’s Media collects and processes the following personal information from you for the purposes set forth below.
| Category | Description and Purpose |
| Contact Information | If you contact us or submit a question via the Site, or download our e-book, we may collect your name, email address, phone number, country, company name, company address, company website URL, your preferred contact method, and the message that you choose to provide. We process Contact Information to operate the Site, to provide our services to you, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. |
| Cookies and Similar Technologies | When you visit the Site, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. We process Cookies and Similar Technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and for usage analytics purposes. We rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business. |
| Usage Information | When you visit the Site, we automatically collect information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address or unique device identifier, domain server, browser type, access time, and data about which pages you visit. We process Usage Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services. |
Personal Information for Which a Third Party is the Controller. As a data controller, the applicable third party collects and processes the following personal information from you. Wright’s Media acts only as a processor with respect to this information.
| Category | Description and Purpose |
| Award Winner Information | When our partners give an award to a product or person, they receive an email from Wright’s Media announcing that they have won. This email also provides information on how they can work with Wright’s to procure the license for use in the winners marketing/promotional materials.Award Winner Information is processed to provide you with products/services, to manage the relationships with you, to communicate with you, and to keep records of communications with you. The legal basis for this processing is the third party’s legitimate interests in the proper administration of its business, the proper management of its customer relationships, and the performance of a contract between you and a third party and/or taking steps, at your request, to enter into such a contract. |
Is entry of personal information required? You may choose not to provide us with any personal information, and you may still access and use much of the Site. However, if you do not provide any personal information, you will not be able to access any portions of the Site that require your personal information.
Other Processing Activities. We may process any of personal information identified in this Policy when necessary for:
- The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
- Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
- Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
- To comply with our legal obligations as well as to keep records of our compliance processes;
- Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- Because you have chosen to publish or display your personal information on a public area of the Site, such as a comment area;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; or
- Because you have expressly given us your consent to process your personal information in a particular manner.
We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.
Cookies and Similar Technologies
First and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.
Other Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website:
- Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s device, web beacons are rendered invisible on web pages when you open a page.
- Social Widgets: These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
- UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Site. The information stored in the cookie is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).
Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.
Hubspot – Wright’s Media uses Hubspot’s platform for our website data collection (CMS), Marketing Communication and CRM (Sales). We use Hubspot’s GDPR and privacy guidance as the basis for our own communications.For more information about Hubspot’s privacy policy, please visit their website. For information about Hubspot’s platform features to support GDPR compliance, please visit the Hubspot GDPR Playbook
| Cookie name | Purpose |
| hsadpixel.neths-banner.com | These cookies are used to track how many times you visit our website once a form submission has been completed. It contains the domain, timestamp of your first, last and current visit to enable a greater user experience on our website. |
WhatConverts. We use WhatConverts to help us quickly capture lead data including contact information and marketing data to help us fulfill lead requests on our website.
LinkedIn Insights. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires (there’s a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag).
DoubleClick.Net. Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
Other Cookies. We also use the following first-party cookies:
| Cookie | Description | Category | Retention |
| __cfruid | This cookie is required to manage incoming traffic and to have better visibility on the origin of a particular request | Strictly Necessary Cookies | Session |
| _dd_s | Cookie from Datadog to provide web performance analytics | Performance Cookies | 24 Hours |
| _cf_bm | The __cf_bm cookie is a cookie necessary to support Cloudflare Bot Management, currently in private beta. As part of our bot management service, this cookie helps manage incoming traffic that matches criteria associated with bots.This is a CloudFoundry cookie | Strictly Necessary Cookies | 30 Minutes |
| __hs_opt_out | This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. | Strictly Necessary Cookies | 6 Months |
| messagesUtk | This cookie is used to recognize visitors who chat with you via the Hubspot chatflows tool | Functional Cookies | 6 Months |
| _hssc | This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics. | Performance Cookies | 24 Hours |
| _fbp | This cookie is placed by Facebook to store and track visits across websites. | Targeting Cookies | 3 Months |
| _hssrc | This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics. | Functional Cookies | Session |
| _conv_v | This cookie is the visitor-centric cookie | Targeting Cookies | 6 Months |
| hs_c2l | Hubspot authentication | Functional Cookies | End of session |
| hubspotapi-csrf | This is used for CSRF prevention – preventing third party websites from accessing your data. | Functional Cookies | 1 Year |
| SEARCH_SAMESITE | allow servers to mitigate the risk of CSRF and information leakage attacks by asserting that a particular cookie should only be sent with requests initiated from the same registrable domain. | Functional Cookies | 2 Years |
| _rdt_uuid | This cookie is set by Reddit and is used for remarketing on reddit.com | Targeting Cookies | 3 Months |
| _hstc | This cookie name is associated with websites built on the HubSpot platform toPe store time of visit. | Performance Cookies | Persistent |
| _ga | This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners._ga | Performance Cookies | 2 Years |
| _gat_UA- | This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites. | Performance Cookies | Persistent |
| _gcl_au | to store a unique user ID. | Targeting Cookies | Persistent |
| _gd############# | This cookie contains no identifying information and is used for diagnostic purposes by Impact Radius, a service we use to track signup commissions for our affiliate program. We have categorized it under Functionality because it is necessary for the operation of our affiliate program. | Functional Cookies | 1 Day |
| gid | This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited._gid | Performance Cookies | 1 day |
| AnalyticsSyncHistory | Used to store information about the time a sync took place with the lms_analytics cookiec | Targeting Cookies | 1 Month |
| bcookie | Browser Identifier cookie to uniquely identify devices accessing LinkedIn to detect abuse on the platform | Targeting Cookies | 2 Years |
| bscookie | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | Targeting Cookies | 2 Years |
| s_tp | Tracks percent of page viewed | Targeting Cookies | 2 Years |
| li_sugr | Used to make a probabilistic match of a user’s identity outside the Designated Countries | Targeting Cookies | 90 Days |
| lms_analytics | Used to identify LinkedIn Members off LinkedIn for analytics | Targeting Cookies | 30 days |
| hubspotutk | This cookie name is associated with websites built on the HubSpot platform. HubSpot report that its purpose is user authentication. As a persistent rather than a session cookie it cannot be classified as Strictly Necessary. | Functional Cookies | 6 months |
| NID | a unique ID Google uses to remember your preferences and other information | Performance Cookies | 6 Months |
| lang | There are many different types of cookies associated with this name, and a more detailed look at how it is used on a particular website is generally recommended. However, in most cases it will likely be used to store language preferences, potentially to serve up content in the stored language. | Targeting Cookies | End of session |
| 1P_JAR | Google cookie. These cookies are used to collect website statistics and track conversion rates. | Targeting Cookies | 30 Days |
| li_gc | This domain is owned by LinkedIn, the business networking platform. It typically acts as a third party host where website owners have placed one of its content sharing buttons in their pages, although its content and services can be embedded in other ways. Although such buttons add functionality to the website they are on, cookies are set regardless of whether or not the visitor has an active Linkedin profile, or agreed to their terms and conditions. For this reason it is classified as a primarily tracking/targeting domain. | Targeting Cookies | 2 Years |
| lidc | To facilitate data center selection | Functional Cookies | 24 Hours |
| wc_client_current | Session cookie used by WhatConverts. | Targeting Cookies | End of Session |
| wc_client | Cookie used by WhatConverts that expires in 179 days | Targeting Cookies | 6 months |
| wc_visitor | Cookie used by WhatConverts that expires in 2 years. | Targeting Cookies | 2 years |
| OptanonAlertBoxClosed | This cookie is set by websites using certain versions of the cookie law compliance solution from OneTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information. | Strictly Necessary Cookies | Persistent |
| OptanonConsent | This cookie is set by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor. | Strictly Necessary Cookies | Persistent |
| s_xxxx | Session cookie | Strictly Necessary Cookies | Persistent |
| UserMatchHistory | This cookie is used to track visitors so that more relevant ads can be presented based on the visitor’s preferences. | Targeting Cookies | 1 Month |
| visitorId | This third-party ZoomInfo cookie is used to collect information about companies that visit our website. We use the information to compile reports about companies interested in our website and to help us improve the website. The cookies collect information in a way that does not directly identify anyone. | Targeting Cookies | 1 Year |
| apbct_timestamp | This period shows the length of the period at which a service can store and/or read certain data from your computer by using a cookie, a pixel, an API, cookieless tracking, or other resources. | Functional Cookies | End of Session |
| apbct_page_hits | This period shows the length of the period at which a service can store and/or read certain data from your computer by using a cookie, a pixel, an API, cookieless tracking, or other resources. | Functional Cookies | End of Session |
| __Secure-3PSIDCC | Used by for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalised Google advertising. | Targeting Cookies | 2 Years |
| __Secure-1PAPISID | Used by for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalised Google advertising. | Targeting Cookies | 2 Years |
| SAPISID | These cookies are used by Google to display personalized advertisements on Google sites, based on recent searches and previous interactions. HSID, SSID, APISID and SAPISID cookies enable Google to collect user information for videos hosted by YouTube. | Targeting Cookies | 2 Years |
| SSID | Google collects visitor information for videos hosted by YouTube on maps integrated with Google Maps. | Targeting Cookies | Persistent |
| SID | These cookies are set via embedded youtube-videos | Targeting Cookies | 2 Years |
| SIDCC | Security cookie to confirm visitor authenticity, prevent fraudulent use of login data and protect visitor data from unauthorized access. | Targeting Cookies | 3 Months |
| APISID | Personalises Google ads on websites based on recent searches and interactions. | Targeting Cookies | 2 Years |
| HSID | Security cookie to confirm visitor authenticity, prevent fraudulent use of login data and protect user data from unauthorized access. | Targeting Cookies | 2 Years |
| __Secure-1PSID | Targeting cookie. Used by for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalised Google advertising. | Targeting Cookies | 2 Years |
| __Secure-3PSID | Builds a profile of website visitor interests to show relevant and personalized ads through retargeting. | Targeting Cookies | 2 Years |
| __Secure-3PAPISID | Builds a profile of website visitor interests to show relevant and personalized ads through retargeting. | Targeting Cookies | 2 Years |
| IR_12893 | to track traffic and sales from affiliate users. | Targeting Cookies | Session |
| apbct_site_landing_ts | This period shows the length of the period at which a service can store and/or read certain data from your computer by using a cookie, a pixel, an API, cookieless tracking, or other resources. | Functional Cookies | End of Session |
| AID | These collect information on the browsing of website users to find out the origin of the visits and othersimilar information at a statistical data. | Targeting Cookies | 1 Year |
| IDE | Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user | Targeting Cookies | 2 Years |
| UULE | A random unique number or string of letters and numbers to identify your browser, the times and dates that you interacted with the site recently and the marketing materials or referring pages that led you to the site. | Performance Cookies | 1 Day |
| s_tslv | Used to retain and fetch time since last visit in Adobe Analytics | Targeting Cookies | 6 Months |
| _gid | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. | Targeting Cookies | 1 Day |
| DV | This cookie is used by Google in combination with HSID to verify a Google user account and most recent login time. This is a security cookie to protect users data from unauthorized access. | Targeting Cookies | 24 Hours |
| s_ppv | Adobe Analytics cookie that indicates previous page viewed. | Performance Cookies | End of Session |
| s_plt | Provides page name value (URL) for use by Adobe Analytics | Performance Cookies | End of Session |
| s_pltp | Provides page name value (URL) for use by Adobe Analytics | Performance Cookies | End of Session |
| s_cc | Used to determine if cookies are enabled for Adobe Analytics | Performance Cookies | End of Session |
| s_tp | Tracks percent of page viewed | Performance Cookies | End of Session |
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow certain cookies via the cookies consent banner or you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265
To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?
When we are acting as the data controller or where permitted by applicable law, we may share your personal information in the following contexts. If we are acting as a data processor, disclosures in the following contexts will be limited in accordance with the instructions from the data controller.
| Category | Disclosure Contexts |
| Corporate Affiliates | We may share your personal information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. |
| Acquisitions and Similar Transactions | We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. |
| 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. We will only disclose your personal information in this context with your consent. |
| Legal Obligations and Rights | We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contract. We may also disclose personal information as needed to protect vital interests. |
| Service Providers | We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; support our provision of services requested by you; send marketing promotions and communications to you about our services; provide technical support; and assist with other legitimate purposes permitted by law. |
| Professional Advisors | We may share your personal information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf. |
| Deidentified or Aggregated Data | We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development. |
HOW LONG DO WE PROCESS YOUR INFORMATION?
We retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.
We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives.
To the extent permitted by law, we may retain and use anonymous, de-identified, aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete data, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it.
We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. If you are a resident of California, please see the California Privacy Rights section for more information.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.
While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.
We use reasonable security measures when transmitting personal information to consumers in response to requests under the California Consumer Privacy Act. We have implemented reasonable security measures to detect fraudulent identify-verification activity and to prevent the authorized access to or deletion of personal information.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.
RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy. If you are exercising a right that is the responsibility of a third party, Wright’s Media will direct you to contact the appropriate data controller who is responsible for responding to your request.
Communication Preferences. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at privacy@wrightsmedia.com and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take action.
Cookies. You may choose to not allow analytic cookies via the cookies consent banner or set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.
Accuracy and Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Complaints. If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.
California Residents
CCPA Notice at Collection. For purposes of the California Consumer Privacy Act (“CCPA”), in collecting the information described above, we collect the categories of personal information listed below. If your information is collected in the context of a business relationship with us, it may not be covered by the CCPA.
| CCPA Category | Description |
| Identifiers | When collecting Contact Information, we will receive your name, email address, telephone number, and company address. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. We use Identifiers as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
| Categories of personal information described in the California Customer Records statute | When collecting Contact Information, we will receive your name, email address, telephone number, company name, and company address. We use Categories of Personal Information described in the California Customer Records statute as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
| Internet or other electronic network activity information | We collect Cookies and Similar Technologies as described in our “Cookies and Similar Technologies” section of this policy. When collecting Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, domain server, browser type, access time, and data about which pages you visit. We use Internet or Other Electronic Network Activity Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
| Geolocation data | When collecting Contact Information, we will receive your address. When collecting Cookies and Similar Technologies and Usage Information we will receive your location while using the Site. We use Geolocation Data as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
| Audio, electronic, visual, thermal, olfactory, or similar information | When collecting Contact Information, we will receive your preferred method of contact and the message that you choose to provide. We use Audio, electronic, Visual, Thermal, Olfactory, or Similar Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
| Professional or employment-related information | When collecting Contact Information, we will receive your work email address, work telephone number, company name, and company address. We use Professional or Employment-Related Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy. |
Data Practices During Last 12 Months
Personal Information Collected: As described in this Policy, we have collected the categories of personal information listed below during the preceding 12 months:
- Identifiers
- Categories of personal information described in the California Customer Records statute
- Internet or other electronic network activity information
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
Categories of Sources: We have collected the personal information identified in this Policy from you.
Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the following purposes:
- Operate the Site;
- Provide our services to you;
- Honor our terms of use and contracts;
- Ensure the privacy and security of our Site and services;
- Maintain our databases and back-ups;
- Manage our relationships with you;
- Communicate with you;
- Keep records of our communications with you;
- Analyze use of the Site and our services;
- Serve you the content and functionality you request;
- Develop new services;
- Enhance your experience;
- Track visits to the Site;
- Provide you with a more personal and interactive experience on the Site; and
- Usage analytics purposes.
Personal Information Sold: We have not sold categories of personal information during the preceding 12 months.
Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months:
- Identifiers
- Categories of personal information described in the California Customer Records statute
- Characteristics of protected classifications
- Commercial information
- Internet or other electronic network activity information
- Geolocation data
We have disclosed each category of personal information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.
No Financial Incentive
We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.
Do Not Sell My Personal Information
Under the CCPA, you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell personal information as defined under applicable law.
CCPA Requests to Know and Requests to Delete
The CCPA gives consumers the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.
However, by way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights.
If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.
Request to Know. As a California resident, you have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.
Submitting a Request
Submission Instructions. You may submit a request to know or to delete via your Account Page or a toll-free telephone call to 1-877-652-5295 or by email to privacy@wrightsmedia.com. Regarding requests to delete, we may present you with the choice to delete select portions of your personal information, but a global option to delete all personal information will be offered and more prominently presented.
Verification Process. We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, account number, address, and telephone number. We will inform you if we cannot verify your identity.
- If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
- If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
- If we cannot verify the identity of the person making a request to delete, we may deny the request.
- If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.
Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.
Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.
CCPA Non-Discrimination
You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.
California Shine the Light
Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at privacy@wrightsmedia.com.
Nevada Residents
You may submit a verified request to us at privacy@wrightsmedia.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law
EU/EEA Residents
If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.
Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.
Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain. If you believe we have not processed your personal information in accordance with applicable provisions of the GDPR, we encourage you to contact us at privacy@wrightsmedia.com. You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
Residents of Brazil
If you are located in Brazil, you have the following rights under the LGPD. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Deletion. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where (1) your situation so requires in order to avoid damage to you, or (2) required to declare your objection or revocation of consent, to avoid processing for specific purposes.
Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Process. You or your representative may establish your legal right to exercise the above rights by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, account number, address, and telephone number. Within 15 days of your request, we will provide you notice of our determination and act as required under your exercise of rights. Where applicable, we will provide a copy of your personal information in compliance with applicable law.
Residents of Australia
If you are located in Australia, you have the following rights under the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs). All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Complain. If you believe we have not processed your personal information in accordance with applicable provisions of the APPs, we encourage you to contact us at privacy@wrightsmedia.com. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
Process. You or your representative may establish your legal right to exercise the above rights by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, account number, address, and telephone number. Within 30 days of your request, we will provide you notice of our determination and act as required under your exercise of rights. Where applicable, we will provide a copy of your personal information in compliance with applicable law.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Wright’s Media is located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
When storing, hosting, or otherwise processing your information (including personal data), we may send such data outside of the European Union (EU), the European Economic Area (EEA), Brazil, and Australia. When we transfer information to the United States or other countries, we do so for the purposes set forth in this Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU, EEA, Brazil, and Australia, such as your express informed consent to do so, when transfer is necessary for us to deliver services pursuant to an agreement between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses. If you are located in Australia and consent to the international disclosure of your personal information pursuant to this policy and your use of the Site or our services, Wright’s Media will not be required to take reasonable steps to ensure the international recipient does not breach the Australian Privacy Principles contained in the Privacy Act.
THIRD-PARTY SITES AND SERVICES
This Policy only applies to the Site, and it does not apply to any third-party websites or applications.
The Site may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left the Site.
We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Site.
Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 16 or younger, nor is information knowingly collected from children under the age of 16. No one under the age of 16 may access, browse, or use the Site or provide any information to or on the Site. If you are under 16, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 16 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 16, please contact us using the contact information provided below.
For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
UPDATES AND CHANGES TO THIS POLICY
We may add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. If we make material changes to how we treat your information, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. Any such changes, updates, or modifications will be effective immediately upon posting on the Site. The date on which this Policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, you should not use the Site.
CONTACT US
For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
In Writing: Wright’s Media
Attn: Privacy Officer
2407 Timberloch Place, Suite B
The Woodlands, TX 77380
By Email: privacy@wrightsmedia.comTelephone: 877-652-5295
Contact Us
2407 Timberloch Place, Suite B
The Woodlands, TX 77380
Toll Free: 887.652.5295
Local: 281.419.5725
Fax: 281.419.5712