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Banks need to be prepared for social-media-fueled runs after SEC rejects
short-selling ban Comcast says it will ‘likely’ sell Hulu stake to Disney,
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PRIVACY POLICY
EFFECTIVE DATE: FEBRUARY 22, 2023
LOOKING FOR TERMS OF SERVICE? CLICK HERE
1. Overview
Please review this Privacy Policy carefully as it describes how Insider,
Inc. (“Insider”) and its affiliates and subsidiaries, including eMarketer,
Inc. (d/b/a Insider Intelligence) (“Intelligence,” and collectively with
Insider Inc., the “Company”, “we”, “our”, or “us”) collect, use, and
disclose information about you as well as your rights and choices about
such use and disclosure. It applies to our websites under the Insider brand
available at www.insider-inc.com, www.businessinsider.com,
www.techinsider.io, www.insider.com, and markets.businessinsider.com; and
under the Intelligence brand, intelligence.businessinsider.com,
www.insiderintelligence.com, and www.emarketer.com(the “Websites”), our
mobile applications that post a link to this Privacy Policy, including the
“Insider” app (“Apps”), and any other online services owned, controlled or
offered by us that post a link to this Privacy Policy (collectively, the
“Service”).
If you have any questions about our privacy practices, please contact us as
set forth in the “Contact Us” section below. If you are a resident of
certain jurisdictions including Nevada, California, Virginia, Europe, or
the United Kingdom, please see the additional disclosures at the end of
this Privacy Policy.
To learn more about our privacy practices with respect to personal
information collected by Insider and Intelligence for employment-related
purposes, please refer to our Employee Privacy Policy and Intelligence
Employee Privacy Policy, respectively.
If you have a disability and would like to access this Privacy Policy in an
alternative format, please review the Insider Inc. Accessibility Statement.
2. Information Collection
For purposes of this Privacy Policy, “personal information” means any
information that relates to an identified or identifiable individual. The
personal information we collect through the Service will be apparent by the
context of the page and/or the circumstances in which the personal
information is being collected. This may include collection and processing
of personal information including, but not limited to, the categories and
types of personal information listed below.
INFORMATION YOU PROVIDE
We collect personal information you provide directly via the Service,
including when you:
* Use our Service, including our Websites and Apps;
* Access our content, including our articles, webinars, research reports
and podcasts;
* Register or update an account;
* Request quotes, product demos, support, information, or access to our
information products and services;
* Subscribe to newsletters, promotional communications, alerts, sales
outreach, updates and other materials;
* Fill in forms, including when you enter competitions, promotions or
surveys;
* Register for events, webinars or other content offers; or
* Contact us.
The categories of personal information we collect include the following:
* Contact Data. We may collect your first and last name, email address,
postal address, phone number, and similar contact data.
* Company Data. Where you interact with us in a business to business
context, we may collect your job title and company name, size, email
address, phone number, and postal address.
* Credentials. When you register for an account with us, we may collect
passwords, password hints, and related information for authentication and
account access.
* Demographic Data. We may collect demographic information including your
country.
* Profile Data. We may collect a personal description, photograph, and
other profile information you submit.
* Payment Data. We use payment processors to collect personal information
necessary to process your payment if you make a purchase with us,
including your payment instrument number (such as a credit or debit card
number), and the security code associated with your payment instrument.
The Company itself does not directly collect or maintain full payment
card information.
* Personal Contacts Data. We may collect personal information you provide
about your contacts, including information about other employees at your
company.
* Content. We collect the content of communications you send to us (such as
feedback and questions to customer support), which may include personal
information.
You may choose to voluntarily submit other information to us through the
Service that we do not request, and, in such instances, you are solely
responsible for such information.
INFORMATION WE AUTOMATICALLY COLLECT
When you access the Service via a web browser, mobile application,
newsletter, or other client, we and other parties use a variety of
technologies, that automatically collect information about your device and
how your device interacts with our Service, which may include personal
information. The categories of information we automatically collect include
the following:
* Service Use Data. We collect data about your interaction with our
Service, the webpage, newsletter, or services feature you were using
before you came to our Service, your web or application request, pages of
our websites that you visit, information you search for via our Service,
access times and dates, and other similar information.
* Device Connectivity and Configuration Data. We collect data about the
type of device or browser you use, your device’s operating software, your
internet service provider, your device’s regional and language settings,
and other similar information. This data also includes IP address, MAC
address, device advertising Id (e.g., IDFA or AAID), and other unique
identifiers for the particular device you use to access the internet.
* Location Data. We collect data about your device’s location, which can be
precise with your consent (e.g., latitude/longitude data) or imprecise
(e.g., location derived from an IP address or data that indicates a city
or postal code level).
We use this information for a variety of purposes (further addressed in
“Our Use of Your Information” below), including analyzing and enhancing our
products and services, personalizing our Service for you, and serving
advertising.
We and other parties automatically collect this information using various
methods, including the following:
* Log Files. Log information is data about your use of the Service, such as
IP address, browser type, internet service provider, referring/exit
pages, operating system, date/time stamps, and related data, which is
stored in log files.
* Cookies. A cookie is a small data file transferred to your computer (or
other device) when it is used to access our Service. Cookies may be used
for many purposes, including to enable certain features of our Service
and remember your preferences, to better understand how you interact with
our Service, to provide you advertising on and off the Service, and to
monitor usage by visitors and online traffic routing. You may be able to
instruct your browser, by changing its options, to stop accepting cookies
or to prompt you before accepting a cookie from the online services you
visit. By clicking "accept", closing the message, or continuing to browse
the Websites, you signify that you understand and agree to the use of
these technologies, as described in this Privacy Policy. You do not have
to accept cookies and consent can be withdrawn at any time, however, you
may not be able to use all portions of our Service or all functionality
of our Service.
* Web Beacons (“Tracking Pixels”). Web beacons are small graphic images,
also known as “internet tags” or “clear gifs,” embedded in web pages and
e-mail messages. Web beacons are used in combination with cookies for
various purposes, including to allow us to count the number of visitors
to the Service, to monitor how users navigate the Service, to count
content views, and to provide you advertising.
* Embedded Scripts. An embedded script is programming code designed to
collect information about your interactions with the Service. It is
temporarily downloaded onto your device from our web server or a third
party with whom we work, is active only while you are connected to the
Service and deleted or deactivated thereafter.
* Click-Through URLs. In some of our e-mail communications, we use a
“click-through URL” linked to content on our websites. When users click
one of these URLs, they pass through a separate web server before
arriving at the destination page on our Websites. We track this
click-through data for various purposes, including to help us determine
interest in particular topics and measure the effectiveness of our
customer communications. If you prefer not to be tracked in this way, you
should not click text or graphic links in the e-mail messages.
* Location-identifying Technologies. GPS (global positioning systems)
software, geo-filtering, and other location-aware technologies locate
(sometimes precisely) you for purposes such as verifying your location
and delivering or restricting relevant content based on your location.
* Device Fingerprinting. Device fingerprinting is the process of analyzing
and combining sets of information elements from your device’s browser,
such as JavaScript objects and installed fonts, in order to create a
“fingerprint” of your device and uniquely identify your device and
applications.
* App Technologies. Our Apps include technologies that are not
browser-based and cannot be controlled by browser settings. Information
may be sent to us and other parties when you install or uninstall mobile
applications or when such Apps periodically contact our and other party
servers. For example, our apps may include SDKs, which is code that sends
information about your use to a server, for instance through the Facebook
SDK. These SDKs allow us to track our conversions, bring you advertising,
and provide you with additional functionality.
For further information on how we use tracking technologies for analytics
and advertising and your rights and choices regarding them, please see the
“Analytics and Advertising Technology” and “Your Rights and Choices”
sections below.
INFORMATION FROM OTHER SOURCES
We also obtain personal information about you from other sources. To the
extent we combine such sourced information with information we have
collected about you on the Service, we will treat the combined personal
information in accordance with the practices described under this Privacy
Policy, plus any additional restrictions imposed by the source of the data.
These sources have included or may include:
* Data brokers from which we purchase demographic data and other personal
information to supplement the personal information we collect.
* Social networks when you reference our Service or grant permission to
Insider to access your personal information on one or more of these
services.
* Our clients or other partners with which we offer co-branded services,
sell or distribute our products, or engage in joint marketing activities.
* Analytics and advertising partners such as advertising exchanges,
advertising servers, data management platforms, content recommendation
platforms and analytics providers provide information to use about your
interaction with our Service or our content on or off our Service.
* Publicly-available sources such as open government databases or other
personal information in the public domain.
We are not responsible for the accuracy of any information provided by
other parties or for their policies or practices.
3. Use of Your Information
We collect and use information for our legitimate interests, including
business and commercial purposes in accordance with the practices described
in this Privacy Policy. Our business purposes for collecting and using
information include:
* To operate and manage our Service, including your registration and
accounts on our Websites;
* To provide the products and services you request and purchase, allow you
to participate in panels, events, sweepstakes and contests, and carry out
the transactions you have requested;
* To provide you with customer support and respond to your questions;
* To communicate with you regarding updates, technical notices, orders,
security alerts, administrative messages, and information regarding
changes to our policies;
* To help authenticate any account you create with us;
* To comply with legal obligations, protect the rights or property of
Insider or Intelligence, our users, or other parties, and prevent fraud
and other prohibited or illegal activities;
* To protect the security of our products, services, and business;
* To enhance and personalize our Service, products and our marketing
efforts;
* To develop and serve advertisements on our Service or through e-mails or
other communications; and
* For our internal purposes (such as auditing, bug detection and error
reporting, data analysis, and research to improve our products, services,
content, advertising, and communications and develop new ones).
We also use your information with your consent, including:
* To administer promotions you have entered; and
* Fulfill any other purpose disclosed to you and with your consent.
Notwithstanding the above, we may use information that does not identify
you (including information that has been aggregated or de-identified) for
any purpose except as prohibited by applicable law. For information on your
rights and choices regarding how we use information about you, please see
the “Your Rights and Choices” section below.
4. Information Sharing and Disclosure
We share your personal information as described in this Privacy Policy. The
types of entities to whom we disclose personal information with include the
following:
OUR SERVICE PROVIDERS
We engage companies and individuals to perform services on our behalf
(e.g., software maintenance services, cloud storage, order fulfillment,
advertising serving technologies, e-mail services, delivery services,
database management, web analytics, credit referencing, payment processing
and other services). These service providers have access to your personal
information so that they may perform these tasks on our behalf and they are
prohibited by us from using or disclosing your information for any purpose
other than to provide this assistance, except to the extent required by
law. We may permit our service providers to use aggregate information which
does not identify you or de-identified data for other purposes, consistent
with applicable law.
AFFILIATES
We share your personal information with our affiliates, related entities,
and holding companies for our and their business and commercial purposes,
including for customer support, marketing, and technical operations.
CLIENTS
We share your personal information with our clients in connection with us
processing your personal information on their behalf. For example, if you
subscribe to our newsletters and promotional communications, Insider or
Intelligence may send you content on behalf of their clients and share your
personal information with such clients for their own marketing purposes.
BUSINESS PARTNERS
We share your personal information with our business partners in connection
with offering you co-branded services, selling or distributing our
products, or engaging in joint marketing activities. In addition, if you
choose to participate in certain of our programs or to receive certain
content we make available (e.g., webinar programs), we may share your
information with participating sponsors, content providers, and related
vendors in connection with such programs and content.
SPONSORS
We may share your email address with sponsors where we get your opt-in
consent for an event.
FACILITATING REQUESTS
We share your personal information to facilitate your requests such as when
you choose to share information with a social network about your activities
on the Service or participate in a business partner’s program.
VENDORS AND OTHER PARTIES
We share personal information with vendors and other parties, for business
and commercial purposes, including analytics and advertising technology
companies that measure and improve our Service, advertising effectiveness
and enable other enhancements. Vendors or such other parties may act as our
service providers, or in certain contexts, independently decide how to
process your information. For more information on practices related to
advertising and analytics, see the “Analytics and Advertising Technology”
section below.
COMPLIANCE WITH LAWS, LEGAL PROCESS AND AUTHORITIES
We cooperate with government and law enforcement officials and private
parties to enforce and comply with the law. We must disclose your personal
information in response to lawful requests by public authorities, including
to meet national security or law enforcement requirements. We may disclose
personal information to government or law enforcement officials or private
parties as we, in our sole discretion, believe necessary or appropriate to
respond to claims and legal process (including but not limited to
subpoenas), to protect the property and rights of us or a third party, to
protect the safety of the public or any person, or to prevent or stop
activity we may consider to be, or to pose a risk of being, illegal,
unethical or legally actionable. We may also disclose information to
protect the rights, property, life, health, security and safety of us, the
Service or any third party.
BUSINESS TRANSFERS
Circumstances may arise where, whether for strategic or other business
reasons, we may sell, transfer or otherwise disclose some or all of our
assets, including your personal information, in connection with a merger,
acquisition, reorganization or sale of assets or in the event of
bankruptcy.
CONSENT AND DISCLOSURE
We share your personal information for purposes disclosed to you and with
your consent.
Without limiting the foregoing, in our sole discretion, we may share
information which does not identify you or de-identified information about
you with third parties or affiliates for any purpose except as prohibited
by applicable law. For information on your rights and choices regarding how
we share your information, please see the section entitled “Your Rights and
Choices” below.
5. Other Parties
Our Service contains links to, or content from, other party’s websites and
other products and services. The fact that we link to a website or display
an advertisement or other party’s content is not an endorsement,
authorization or representation of our affiliation with any of those other
parties, nor is it an endorsement of their privacy or information security
policies or practices.
We do not exercise control over other parties’ websites, products or
services, and whether they store information in the U.S. or elsewhere.
These other products and services may place their own cookies or other
technologies on your computer or other device, collect data, or solicit
information from you. Other persons and entities follow different rules
regarding the use or disclosure of the information you submit to them or
they collect from you. We encourage you to learn about the privacy
practices of those other parties.
6. Social Media Services and Technology Integrations
BLOGS, SOCIAL MEDIA AND OTHER PUBLIC FORUMS
We may offer blogs, social media profiles, message boards, bulletin boards
or similar public forums where you and other users of our Service can post
content or otherwise communicate. If you post personal information on a
public forum, we will assume you intend to make that personal information
public. We may use your name to identify you with a posting in a public
forum and may use your post on or in connection with our Service (e.g.,
when using a hashtag associated with Insider in a tweet or status update).
Any personal information you share in a public forum is public information
and may be seen or collected by other persons, including third parties that
do not adhere to the standards set forth in this Privacy Policy. We are not
responsible for events arising from the distribution of any information you
choose to publicly post or share through our online services.
In addition, to the extent you interact with social networks or other
services through the Service (such as “liking” or “sharing” our content or
otherwise connecting our Service to a social network), understand that
information collected and stored by those other parties through your
interaction or pages that contain their tracking technologies remains
subject to their policies and practices, including whether they share
information about you with us, the types of information shared, and your
choices on what is visible to others. We are not responsible for and make
no representations regarding the policies or business practices of any
other parties or their services and encourage you to familiarize yourself
with and consult their privacy policies and terms of use.
ANALYTICS AND ADVERTISING TECHNOLOGY
Our Service contains tracking technologies owned and operated by other
parties. For example, we use tracking technologies from analytics services,
such as Google Analytics, to help us understand how users access and use
the Service.
We also work with ad networks, advertisers, agencies, and other technology
services to place advertisements on the Service and/or other websites and
services. For example, we place ads through Google and Facebook that you
may view on their platforms as well as on other websites and services.
These parties may set and access cookies and other technologies on your
personal computer and/or device and track certain behavioral information
regarding users of your personal computer and/or device. These cookies and
other technologies are set to, among other things: (a) track your
activities across time and services for purposes of measuring conversions
or actions you take, associating different devices you use, and serving ads
and/or other content targeted to your interests (“Interest-based
Advertising”); (b) prevent you from seeing the same advertisements too many
times; and (c) understand the usefulness to you of the advertisements that
have been delivered to you.
We also work with ad networks, advertisers, agencies, and other technology
services to place advertisements on the Service and/or other websites and
services. For example, we place ads through Google and Facebook that you
may view on their platforms as well as on other websites and services.
These parties may set and access cookies and other technologies on your
personal computer and/or device and track certain behavioral information
regarding users of your personal computer and/or device. These cookies and
other technologies are set to, among other things: (a) track your
activities across time and services for purposes of measuring conversions
or actions you take, associating different devices you use, and serving ads
and/or other content targeted to your interests (“Interest-based
Advertising”); (b) prevent you from seeing the same advertisements too many
times; and (c) understand the usefulness to you of the advertisements that
have been delivered to you.
We also use audience matching services (which is a type of Interest-Based
Advertising) to reach people (or people similar to people) who have visited
our Services or are identified in one or more of our databases (“Matched
Ads”). This is done by us sharing a list of hashed emails with an ad
partner or incorporating a pixel or SDK from an ad partner into our own
Services, and the ad partner matching common factors between our data and
their data or other datasets. For instance, we use Facebook Custom
Audiences to serve ads to our customers on Facebook and Facebook Lookalike
Audiences to serve ads to users on Facebook similar to our customers.
As discussed above, vendors and ad partners may act as our service
providers, or in certain contexts, independently decide how to process your
information. We encourage you to familiarize yourself with and consult
their privacy policies and terms of use. For further information on your
choices regarding these third party tracking technologies, please see the
sections entitled “Information We Automatically Collect” above and “Your
Rights and Choices” below.
7. Your Rights and Choices
ACCOUNTS
Depending on the account, you may be able to access information that you
have voluntarily provided to Insider or Intelligence through your account
on the Service, and to review, correct, or delete it by following the
instructions on the Service. For example, if you have a subscriber account
there are additional functions available within your account settings to
exercise your rights and choices concerning the information you provide.
Meanwhile, other accounts may not have the same functionality. Please note
that your Insider account and Intelligence account (if you are subscribed
to both) are not linked and changes to, or the deletion of, one account
will not change or delete any other account. You will need to access each
account separately to make the same changes or to delete the account, if
applicable.
Alternatively, if your account does not offer the functionality to edit the
information in your account settings, you can contact Insider in writing as
set forth in the section entitled “Contact Us” below. We may require
additional information from you to allow us to confirm your identity.
Please note we will retain and use your data, including server/backup
copies, to comply with our legal obligations, resolve disputes, and enforce
our agreements, and we may decline to process change or deletion requests
that require disproportionate technical effort or jeopardize the privacy of
others.
TRACKING TECHNOLOGIES GENERALLY
Cookies and location-identifying technologies may generally be disabled or
removed by tools available as part of most commercial browsers, and in some
instances blocked in the future by selecting certain settings. Browsers
offer different functionalities and options so you may need to set them
separately. You can stop all collection of information via our mobile
application by uninstalling it. Also, you may be able to exercise specific
privacy choices, such as enabling or disabling certain location-based
services, by adjusting the permissions in your mobile device. Please be
aware that if you disable or remove these technologies some parts of the
Service may not work and that when you revisit the Service your ability to
limit browser-based tracking technologies is subject to your browser
settings and limitations.
DO NOT TRACK
Your browser settings may allow you to automatically transmit a “Do Not
Track” signal to online services you visit. Note, however, there is no
industry consensus as to what site and app operators should do with regard
to these signals. Accordingly, unless and until the law is interpreted to
require us to do so, we do not monitor or take action with respect to “Do
Not Track” signals or other mechanisms. For more information on “Do Not
Track,” visit http://www.allaboutdnt.com
ANALYTICS AND ADVERTISING TRACKING TECHNOLOGIES
You may exercise choices regarding the use of cookies from Google Analytics
by going to https://tools.google.com/dlpage/gaoptout and downloading the
Google Analytics Opt-out Browser Add-on.
Some of the advertisers and vendors that perform advertising-related
services for us and our partners participate in the Digital Advertising
Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.
To learn more about how you can exercise certain choices regarding
Interest-based Advertising, visit http://www.aboutads.info/choices, and
http://www.aboutads.info/appchoices for information on the DAA’s opt-out
program for mobile applications. Some of these companies are also members
of the Network Advertising Initiative (“NAI”). To learn more about the NAI
and your opt-out options for their members, see
http://www.networkadvertising.org/choices/.
To opt out of us sharing your hashed email address for Matched Ads, please
contact us at privacy@insider-inc.com and specify that you wish to opt out
of Matched Ads. We will remove your email address from any subsequent lists
shared with ad partners for purposes of Matched Ads.
Please be aware that, even if you are able to opt out of certain kinds of
Interest-based Advertising, you may continue to receive other types of ads.
Opting out only means that those selected members should no longer deliver
certain Interest-based Advertising to you but does not mean you will no
longer receive any targeted content and/or ads (e.g., from other ad
networks). Insider is not responsible for effectiveness of, or compliance
with, any third parties’ opt-out options or programs or the accuracy of
their statements regarding their programs.
COMMUNICATIONS
If you decide at any time that you no longer wish to receive newsletters or
promotional communications from us, please follow any unsubscribe
instructions provided in our communications to you, update your user
preferences via our subscription management tools on our Service, or
contact us as set forth in the section below entitled “Contact Us” and
specify your request. Please note that you cannot opt out of
non-promotional e-mails, and we may use your information to contact you
with important notifications, such as notices with respect to purchases,
safety, or changes to our terms, conditions, and policies. Also, your
opt-out is limited to the e-mail address or phone number used and will not
affect subsequent subscriptions.
OTHER RIGHTS SPECIFIC TO YOUR LOCATION
Residents of certain jurisdictions, including Nevada, California, Virginia,
the European Economic Area, and the United Kingdom, have specific rights
with respect to our collection, use, and sharing of personal information.
Please review our location-specific sections below for more information
about those rights.
8. Security and Data Retention
We employ appropriate security measures designed to protect your
information from unauthorized access, alteration, disclosure, or
destruction. Please be advised, however, that while we strive to protect
your information and privacy, we cannot guarantee or warrant the security
of any information you disclose or transmit to us online and are not
responsible for the theft, destruction or inadvertent disclosure of your
information.
If you suspect unauthorized use of personal information that you have
provided us – such as your account information or its credentials – you
should notify us immediately using the information in the Contact Us
section at the end of this Privacy Policy.
9. International Transfer
Insider is based in the U.S. and the personal information we collect is
governed by U.S. law. Insider processes personal information on our servers
in the U.S. and other jurisdictions. Your personal information may be
transferred to, and used, in locations outside of your state, province,
country or other governmental jurisdiction where the privacy laws may be
different than those in your jurisdiction. Your use of the Service or
provision of any personal information constitutes your consent to the
transfer to and from, processing, usage, sharing, and storage of your
information in the U.S. and other jurisdictions as set forth in this
Privacy Policy.
To the extent that the Company offers products and services to individuals
located in the European Economic Area or United Kingdom, or to the extent
the Service is intentionally available to such individuals, please review
the section titled “Additional Disclosures for Data Subjects in Europe”
below for more information about disclosures and privacy rights associated
with that activity.
10. Our Policy Toward Children
We do not knowingly collect personal information as defined by the U.S.
Children’s Privacy Protection Act (“COPPA”) from children under 13. We
encourage parents and guardians to take an active role in their children’s
online activities and interests. If you are a parent or guardian and
believe we have collected information in a manner not permitted by COPPA,
please contact us at privacy@insider-inc.com and we will remove such
information to the extent required by COPPA. We also do not knowingly
“sell” the personal information of minors under 16 who are California
residents without their affirmative authorization.
11. Changes to this Privacy Policy
We reserve the right to update this Privacy Policy at any time. If we make
changes, we will revise this Privacy Policy to reflect such changes and
revise the effective date included at the beginning of this policy. We may
provide you additional notice (such as to your e-mail address) if the
changes are material. Your use of the Service following any such notice
will signify and constitute your assent to and acceptance of such revised
Privacy Policy.
12. Contact Us
If you have any questions about this Privacy Policy, including our
compliance with applicable law, please feel free to contact Insider
directly:
* By e-mail at privacy@insider-inc.com
* For EU specific questions, please email us at euprivacy@insider-inc.com.
* If you have a disability and would like to access this Privacy Policy in
an alternative format, please review the Insider Inc. Accessibility
Statement.
13. Additional Disclosures for California Residents
These additional disclosures apply only to individuals who are California
residents. The California Consumer Privacy Act of 2018, including as
amended by the California Privacy Rights Act of 2020 (“CCPA”) provides
additional rights to know, delete, correct, limit, and opt out, and
requires businesses collecting or disclosing personal information to
provide notices and means to exercise rights. California residents also
have the right not to receive discriminatory treatment by us for the
exercise of your privacy rights under the CCPA.
For the purposes of this Section 13, except where a different definition is
noted, “personal information” means information that identifies, relates
to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular resident or
household. Personal information does not include publicly available
information; lawfully obtained, truthful information that is a matter of
public concern; information that has been de-identified or aggregated; or
other information covered by certain sector-specific privacy laws, as
consistent with state law. Any capitalized term used and not otherwise
defined below has the meaning assigned to it in our Privacy Policy .
A. PERSONAL INFORMATION WE COLLECT
In the past 12 months, we have collected the following categories of
personal information enumerated in the CCPA:
* Identifiers, including name, email address, phone number, address,
account name and password (and other information used for authentication
purposes), IP address, ID or number assigned to your account or device.
* Personal information described in California Civil Code § 1798.80(e),
including name, phone number, address, physical characteristics or
description, and billing and shipping address and credit or debit card
information, to the extent collected by our payment processors on our
behalf as necessary to process payments with us.
* Characteristics protected under California or federal law, such as your
age, gender, country of origin or residence, and other information you
may provide in connection with your profile on our Service.
* Commercial information, including our Services that you have purchased,
obtained, or considered; and/or other purchasing or consumer histories,
tendencies, and preferences.
* Internet or other electronic network activity information, including your
interactions with our Service and other information disclosed in Sections
2 and 6 of this Privacy Policy.
* Geolocation data, including location enabled services such as WiFi and
GPS.
* Audio, electronic, visual, thermal, olfactory, or similar information,
which includes photographic images; and call and voicemail recordings.
* Professional and employment-related information, such as your job title
and company name, size, email address, phone number, postal address, and
related information regarding employees and other representatives of our
enterprise clients.
* Inferences, including information about your interests, preferences and
favorites.
Please note that because of the overlapping nature of certain of the
categories of personal information identified above, which are required by
state law, some of the personal information we collect may be reasonably
classified under multiple categories.
Sensitive personal information. Certain of the personal information that we
collect, as described above, may constitute “sensitive personal
information” as defined by California law, including:
* Account log-in number combined with required security or access codes,
passwords, or other credentials allowing access to an account; and
* Precise geolocation.
B. SOURCES OF COLLECTED PERSONAL INFORMATION
For more information on the sources from which we have collected personal
information in the past 12 months, review the “Information Collection”
section above.
C. WHAT WE DO WITH YOUR PERSONAL INFORMATION
We collect and use these categories of personal information for the
business purposes described in the “Use of Your Information” section,
including to operate and manage our Services.
The types of sensitive personal information that we collect as described in
Section 13(a) above may be used for the following purposes:
Category of Sensitive Personal InformationPurpose(s)Account log-in number
combined with required security or access codes, passwords, or other
credentials allowing access to an accountTo operate and manage our Service,
including your registration and accounts on our Websites; to help
authenticate any account you create with usPrecise geolocationTo operate
and manage our Service, including your registration and accounts on our
Websites; to provide the products and services you request and purchase,
allow you to participate in panels, events, sweepstakes and contests, and
carry out the transactions you have requested; to enhance and personalize
our Service, products and our marketing efforts; to develop and serve
advertisements on our Service or through e-mails or other communications;
for our internal purposes (such as auditing, bug detection and error
reporting, data analysis, and research to improve our products, services,
content, advertising, and communications and develop new ones)
We will retain personal information for as long as needed or permitted in
light of the purpose(s) for which it was obtained. The criteria used to
determine our retention periods include: (i) the length of time we have an
ongoing relationship with you; (ii) whether you have provided, and the
nature of, your directions and/or consent to us or others; (iii) whether
there is a legal obligation to which we are subject; (iv) whether there is
a privacy right for which the personal information has been exercised (such
as a request to delete); and (v) whether retention is advisable in light of
our legal position (such as in regard to applicable statutes of
limitations, litigation or regulatory investigations).
D. WHO WE DISCLOSE PERSONAL INFORMATION TO
We disclose the categories of personal information to the categories of
service providers and third parties identified in Section 4 above, and in
the ways described in that section.
This includes disclosure of your personal information to service providers
for a business purpose. When we disclose personal information for a
business purpose, we enter a contract that describes the purpose and
requires the recipient to both keep that personal information confidential
and not to use it for any purpose except performing the contract. In the
preceding twelve (12) months, we have disclosed each category of personal
information listed in Section 13(a), including the listed sensitive
personal information, for one or more of the business purposes detailed in
this Privacy Policy.
The Company “sells/shares” personal information as defined by the CCPA to
the extent the Company engages third parties to use tracking technologies
on its Services, including for cross-context behavioral advertising and
other purposes detailed in Sections 2, 4, and 6 of this Privacy Policy.
Specifically, as with many online companies, Insider and Intelligence
partners with third parties to show you personalized ads on behalf of
advertisers and to manage our marketing on other platforms, where such
advertising is based on your past visits to our Service, as well as certain
analytics. These third party partners may use tracking technologies, such
as cookies, to gather information about your activities on the Service, or
on other platforms, to deliver such advertising to you when you visit our
Services or other third party platforms. For instance, advertisers may
provide us with certain information that enables us to show personalized
advertisements to you on our Services on behalf of those advertisers. As
another example, if you visit our Websites, a cookie may be attached to
your browser that allows us to deliver advertising to you on other third
party platforms. Please also review our disclosures in Sections 2 and 6 of
this Privacy Policy.
The Company also “sells/shares” personal information with third parties to
facilitate other advertising to you by us and others, such as for data
enrichment, audience matching, and analytics services.
In the last twelve (12) months, we have ”sold”/“shared” the following
categories of personal information to third parties, including to
advertising and marketing partners and data analytics providers:
* Identifiers
* Characteristics protected under California or federal law
* Commercial information
* Internet or other electronic network activity information
* Geolocation data, including precise geolocation
* Inferences
Please review the “Information Sharing and Disclosure” section for more
detail about the parties with whom we have shared personal information in
the past 12 months.
E. YOUR PRIVACY RIGHTS
The CCPA provides California residents with specific privacy rights
regarding their personal information. This section describes your CCPA
rights and explains how to exercise those rights.
If you are a California resident, you have the right to make the following
requests under applicable California law in relation to your personal
information, subject to certain exceptions:
* Right to Know. You have the right to, up to twice in a 12-month period,
request what personal information we collect, use, disclose, and/or sell,
and to whom, as applicable. You may request either a report disclosing
the general categories of the personal information we collect, or a
report disclosing the specific pieces of personal information we collect.
* Right to Delete. You have the right to request, under certain
circumstances, the deletion of your personal information that we collect.
* Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the
“sale” or “sharing” of your personal information, as those terms are
defined under California law. As disclosed in Section 13(d) above, the
Company “sells/shares” your personal information with third parties for
cross-context behavioral advertising and certain analytics. Please review
our “Notice of Right to Opt-Out” below for more information about how to
exercise this right.
* Right to Limit Use and Disclosure. You have the right to limit the use or
disclosure of your sensitive personal information to only the uses
necessary for us to provide our Products and Services to you, or for
certain other authorized purposes. We will not use or disclose your
sensitive personal information after you have exercised your right unless
you subsequently provide consent for the use of your sensitive personal
information for additional purposes.
* Right to Correct. You have the right to request the correction of your
inaccurate personal information.
* Right to Non-Discrimination. You have the right not to receive
discriminatory treatment for the exercise of the privacy rights described
above.
How to submit a request. To exercise any of these rights, please submit a
request in one of the following ways:
* For Insider, click here and follow the instructions.
* For Intelligence, please email us at privacy@insiderintelligence.com with
details of your request.
* Email us at privacy@insider-inc.com with respect to Insider, Inc.
We will confirm receipt of your request within 10 business days. We may
require, or provide you with the opportunity to provide, additional
information from you to help us verify your identity and process your
request. If we are unable to verify your identity, we may deny your
requests to know or delete.
If personal information about you has been processed by us as a service
provider on behalf of a client and you wish to exercise any rights you have
with such personal information, please inquire with our client directly. If
you wish to make your request directly to us, please provide the name of
our client on whose behalf we processed your personal information. We will
refer your request to that client and will support them to the extent
required by applicable law in responding to your request.
Requests by authorized agents. You may designate an authorized agent, in
writing or through a power of attorney, to request to exercise the above
rights on your behalf. If you should use an authorized agent to exercise
your various rights under the CCPA, we require that you provide your
authorized agent with written permission to exercise your various rights
and to verify your own identity with us. If your authorized agent does not
submit proof that they have been authorized by you to submit verified
requests for disclosure and deletion, we reserve the right to deny such a
request that we have received and will explain to your authorized agent why
we have denied such request.
F. NOTICE OF RIGHT TO OPT-OUT
As described in Section 13(d) above, the Company “sells/shares” personal
information as defined by the CCPA . You may opt-out of the sale/sharing of
your personal information at any time by submitting a request to opt-out by
clicking the “Your Privacy Choices” link in the footer of our Websites, by
clicking here and following the instructions, or by emailing Insider at
privacy@insider-inc.com. For requests to Intelligence, please email us at
privacy@insiderintelligence.com.
G. NOTICE OF FINANCIAL INCENTIVES
We may offer incentives on products or services, such as discounts or
exclusive offers, by enrolling in newsletters or other programs. If and
when we offer such programs, we will ask for certain of your personal
information in order to become eligible for the incentives. The programs
that may potentially be available to you are:
* Insider Reviews Newsletter. If you sign up for our Insider Reviews
Newsletter, you will receive exclusive deals and independent product
reviews. In order to participate, you need to visit Insider’s
“Newsletters” page accessible here and provide your email address.
Please be advised that promotions offered by Insider Coupons are not owned
or operated by us. For information about Insider Coupons’ privacy
practices, including its promotions, please visit their website at
www.coupons.businessinsider.com.
H. SHINE THE LIGHT
Customers who are residents of California may request (i) a list of the
categories of personal information disclosed by us to third parties during
the immediately preceding calendar year for those third parties’ own direct
marketing purposes; and (ii) a list of the categories of third parties to
whom we disclosed such information. To exercise a request, please write us
at the email or postal address set out in “Contact Us” section above and
specify that you are making a “California Shine the Light Request.” We may
require additional information from you to allow us to verify your identity
and are only required to respond to requests once during any calendar year.
14. Additional Disclosures for Data Subjects in Europe
These additional disclosures apply only to individuals who are Virginia
residents. The Virginia Consumer Data Protection Act (“VCDPA”) provides
additional rights and requires businesses collecting or disclosing personal
information to provide notices and means to exercise rights.
For the purposes of this section, except where a different definition is
noted, “personal information” means any information that is linked or
reasonably linkable to an identified or identifiable natural person.
Personal information does not include de-identified data or publicly
available information. For purposes of this section, publicly available
information means information that is lawfully made available through
federal, state, or local government records, or information that a business
has a reasonable basis to believe is lawfully made available to the general
public through widely distributed media, by the consumer, or by a person to
whom the consumer has disclosed the information, unless the consumer has
restricted the information to a specific audience
A. WHAT INFORMATION WE COLLECT
We may collect the personal information from or about you as detailed in
Sections 2 and 13(a) of this Privacy Policy. Certain of the personal
information described above constitutes “sensitive personal data” as
defined under Virginia law:
* Precise geolocation data
B. WHAT WE DO WITH YOUR INFORMATION
We may collect or use personal information from you for the purposes
identified in Sections 3 and 13(c) of this Privacy Policy. To the extent we
collect sensitive personal information as identified in Section 14(a)
above, it may be used for all of these purposes.
C. WHO WE SHARE INFORMATION WITH
We may share any of the categories of personal information identified above
with our service providers receiving information to perform services for us
on our behalf.
We do not “sell” your personal information as that term is defined under
Virginia law, which is limited to the exchange of personal information to a
third party for monetary consideration.
As detailed elsewhere in this Privacy Policy, we do share personal
information that is gathered when you visit our Service, such as cookies
and pixels, with third parties for targeted advertising purposes. You may
opt-out of such sharing by following the instructions provided in Section
14(d) below.
D. YOUR PRIVACY RIGHTS
If you are a Virginia resident, you have the following rights under
Virginia law with respect to your personal information:
* Right to Access. You have the right to request what personal information
we collect, which may include requests to obtain a copy of such
information in a portable and readily usable format, in certain
circumstances.
* Right to Correct. You have the right to request the correction of any of
your personal information that you believe to be inaccurate.
* Right to Delete. You have the right to request the deletion of your
personal information that is collected and maintained by us.
* Right to Opt-Out. You have the right to opt-out of our processing of your
personal information for purposes of (i) targeted advertising, (ii) the
sale of personal data, or (iii) profiling.
* Right to Non-Discrimination. You have the right not to receive
discriminatory treatment by us for the exercise of the privacy rights
described above.
The above rights are subject to our being able to reasonably verify your
identity and authority to make these requests. These rights are also
subject to various exclusions and exceptions under applicable laws. We will
verify your identity by using data you provide, such as first name, last
name, and email address. These data elements will be compared against our
records for verification.
If you are a Virginia resident and wish to exercise these rights, please
reach us in one of the following ways:
* Click here and follow the instructions (Insider only)
* For Insider, email at privacy@insider-inc.com; and for Intelligence,
email your request at privacy@insiderintelligence.com.
If you wish to appeal our decision with regard to a request that you have
previously made, please contact us using the information above or notify
the Office of the Attorney General of Virginia by clicking here.
15. Additional Disclosures For Data Subjects In Europe and United Kingdom
DATA CONTROLLER
This section applies to any individuals located within the European
Economic Area (EEA), United Kingdom (UK), Switzerland, or any jurisdiction
to which similar privacy laws apply, from whom we may have collected
personal data from any source, including through your use of our Services.
We provide this Notice to comply with applicable privacy laws, including
the General Data Protection Act (“GDPR”), the UK GDPR, and related laws,
regulations, and guidance from the European Union and/or its member states.
Any capitalized term used and not otherwise defined below has the meaning
assigned to it in our Privacy Policy.
For the purposes of this Notice, “personal data” means any information
relating to an identified or identifiable natural person.
EU and UK data protection law makes a distinction between organizations
that process personal data for their own purposes (known as “data
controllers”) and organizations that process personal data on behalf of
other organizations (known as “data processors”). Both Insider and
Intelligence may act as either a data controller or a data processor in
respect of your personal data, depending on the circumstances. We generally
act as data controller with respect to information you provide through the
Service. Sometimes we operate as a data processor on behalf of a client, a
separate legal entity, which is the data controller. For example, if you
subscribe to our newsletters and promotional communications, we may send
you content on behalf of our clients and share your personal data with our
clients for their own marketing purposes. Please visit the applicable
client’s privacy policy for information about their privacy practices. Any
questions that you may have relating to such personal data and your rights
under data protection law should therefore be directed to the client as the
data controller, not to Insider or Intelligence.
BASIS FOR PROCESSING YOUR PERSONAL DATA
We rely on one or more legal bases to process your personal data under
applicable law. We may process personal data (i) as necessary to perform
our contractual obligations to you, including, but not limited to, those
obligations in our terms of use; (ii) as necessary to pursue our legitimate
interests as further detailed below; (iii) as necessary for our compliance
with our legal obligations such as a request or order from courts, law
enforcement or other government authorities; and/or (iv) with your consent,
including to send you marketing email messages and other information that
may be of interest to you, which you may withdraw at any time.
Legitimate business interests. We may collect, process, and maintain
personal data to pursue the legitimate business interests outlined below.
To determine these legitimate interests, we balance our legitimate
interests against the legitimate interests and rights of you and others and
only process personal data in accordance with those interests where they
are not overridden by your data-protection interests or fundamental rights
and freedoms.
While our legitimate interests are most extensively detailed in Section 3
of this Privacy Policy, they generally include:
* Provide, improve, and develop our Websites, Apps, and Services, including
to deliver your requested Services, send you messages and provide user
support, customize the Services to better fit your needs as a user,
develop new Services, and perform internal analytics and research and
development. This also includes sharing personal data with our trusted
service providers that provide services on our behalf.
* Protect you and others and to create and maintain a trusted environment,
such as to comply with our legal obligations, to ensure compliance our
agreements with you and other third parties, to ensure safe, secure, and
reliable Services, and to detect and prevent wrongdoing and crime, assure
compliance with our policies, and protect and defend our rights,
interests, and property. In connection with the activities above, we may
conduct internal research and profiling based on your interactions on
various Sites, content you submit to the Sites, and information obtained
from third parties.
* Provide, personalize, measure and improve our marketing, including to
send you promotional messages and other information that may be of
interest to you with your consent. We may also use personal data to
understand our user base and the effectiveness of our marketing. This
processing is done pursuant to our legitimate interest in undertaking
marketing activities to offer products or services that may be of
interest to you.
YOUR PRIVACY RIGHTS
If you are a data subject in a jurisdiction identified in this section, you
have the right to access, rectify, or erase any personal data we have
collected about you through the Service. You also have the right to data
portability and the right to restrict or object to our processing of
personal data we have collected about you through the Service. In addition,
you have the right to ask us not to process your personal data (or provide
it to third parties to process) for marketing purposes or purposes
materially different than for which it was originally collected or
subsequently authorized by you. You may withdraw your consent at any time
for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please click on the “Your Privacy Choices”
link in the footer of Insider’s websites and follow the instructions, or
contact us as at privacy@insider-inc.com and specify which right you intend
to exercise. For Intelligence, please email your request at
privacy@insiderintelligence.com. We will respond to your request within 30
days. We may require additional information from you to allow us to confirm
your identity. Further, if we are processing your information on behalf of
one of our clients, we will refer you to that client, and will support them
to the extent required by applicable law in responding to your request.
Please note that we store information as necessary to fulfill the purposes
for which it was collected, and may continue to retain and use the
information even after a data subject request for purposes of our
legitimate interests, including as necessary to comply with our legal
obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance or you believe that we have not
complied with our obligations under this Privacy Policy or European or UK
law, you have the right to make a complaint to an EU Data Protection
Authority, such as the UK Information Commissioner's Office. You can view
the contact information for your data protection authority here.
DATA RETENTION
We will only retain your information for as long as necessary to fulfill
the purposes we collected it for. We will retain and use your information
as necessary to satisfy any legal, accounting or reporting requirements, to
resolve disputes or to enforce our agreements and rights. In line with this
Privacy Policy, we will either securely delete or anonymize your data so
that it cannot be linked back to you.
DATA TRANSFER
We will not transfer personal data originating from the EU to third parties
located outside of the EU without ensuring adequate protection under
European or UK law. Where transfer is to a party located in a third country
not recognized by the EU Commission as ensuring an adequate level of
protection, we will take appropriate steps to transfer the personal data
subject to adequate safeguards, such as standard contractual clauses as
well as other appropriate measures and safeguards.
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