Last updated June 20th, 2019
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1. What Personal Information Do We Gather About You?
When you use the U of Digital Services by, among other actions, ordering a subscription or other product, providing registration details, setting newsletter preferences, browsing our sites, completing a survey, entering a contest or otherwise interacting with our U of Digital Services, we gather personal information. Personal information is information that identifies you as an individual or relates to an identifiable individual. Several different types of personal information can be gathered when you interact with the U of Digital Services, depending on the type of product or service being used. Collection of personal information is necessary to delivering you the U of Digital Services and to enhance your customer experience.
We and our service providers collect personal information in a variety of ways, including:
A) Through the U of Digital Services.
i. Registration: When you register for a U of Digital Service, we collect personal information. Registration to an event or conference requires that you complete a form that will include, at a minimum, your name and email address.
ii. Billing: To subscribe to a U of Digital Service or enable payment via the U of Digital Services, we may collect and use your name, address, telephone number, email address, credit or debit card information and other billing information.
iii. User-Generated Content and Public Activities (Including Comments and Reviews): We offer you opportunities to engage in public activities on U of Digital Services. “Public activities” are any actions you take on U of Digital Services that are designed to be visible to other users, including comments, recommendations, reviews, ratings or any other items that you submit. If you choose to engage in public activities, any personal information you submit can be read, collected and used by other users of these services. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions (except as required by applicable laws).
iv. Contests, Sweepstakes and Special Offers: U of Digital collects personal information, such as your name and email, from you when you participate in sweepstakes, contests or special offers.
v. Reader Surveys, Reader Panels and Market Research: We and our service providers collect personal information from you through voluntary surveys or feedback programs conducted via the U of Digital Services, through our service providers’ platforms, by phone, by mail or during in-person interviews or focus groups.
vi. Reader Experience Programs: When you interact with our interactive programs and answer questionnaires, we collect personal information about you.
2. What Do We Do With The Personal Information We Collect About You?
We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:
– The consent you provide to us at the point of collection of your personal information;
– The performance of the contract we have with you;
– The compliance of a legal obligation to which we are subject; or
– The legitimate interests of U of Digital, a third party or yourself. “Legitimate interest” is a technical term under the regulation. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. “Legitimate interest” also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within U of Digital; and (3) to prevent fraud.
A) Provide the U of Digital Services You Request. We use the information we gather about you to enable your use of the U of Digital Services and fulfill your requests for certain products and services, such as providing the U of Digital Services’ functionality to you, arranging access to your registered account, providing you with customer service, responding to your inquiries, requests, questions, suggestions, compliments or complaints, completing your transactions, sending you administrative information, and enabling you to participate in and renew paid services, polls, promotions, surveys, panels or research, and message boards. We will engage in these activities to manage our contractual relationship with you or comply with a legal obligation.
B) Analysis and Development of New Products and Services. We perform statistical, demographic and marketing analyses of users of the U of Digital Services, and their subscribing and purchasing patterns, so we can analyze or predict our users’ preferences for product and services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest in doing so.
C) Customizing Your Experience. We use the information that we have to better understand you and customize certain features of the U of Digital Services to provide you with an enhanced experience. We will provide personalized services because we have a legitimate interest.
E) Administrative Purposes. We and our service providers use the information we have about you for the following legitimate business purposes:
For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
To understand and assess satisfaction with our U of Digital Services or our customer care team.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest.
F) Allowing You to Participate in Sweepstakes, Contests or Other Promotions. We may offer you the opportunity to participate in a sweepstakes, contest or other promotions. Some of these promotions have additional rules containing information about how we will use and disclose your personal information. We use this information to manage our contractual relationship with you.
G) Aggregating and/or Anonymising Personal Information. We aggregate and/or anonymize personal information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.
3. With Whom Do We Share The Personal Information We Gather?
A) Sharing Within U of Digital.
B) Sharing With Service Providers. We contract with other companies, agents or contractors (“service providers”) to provide services on our behalf. These services are, for example, credit-card, payment and billing processing, fulfillment of orders, information technology and related infrastructure provision, customer service, ad serving, shipping, email distribution, list processing and analytics, research surveys/interviews/focus group management and analysis, or promotions management. In the course of performing these services, our service providers have access to your information including your personal information.
i. We may share personal information, such as name, company and title, about attendees to our live events and conferences with sponsors; if we do, we will notify you when you provide us the information.
ii. We may also share personal information to third-party sponsors of sweepstakes, contests, and similar promotions and will let you know at the point of collection of your information if we do.
iv. We share in aggregate results from research surveys or panels with advertisers.
v. We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
D) Compliance With Legal Process. We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of the U of Digital Services; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).
E) By Using the U of Digital Services, You May Elect to Disclose Personal Information.
i) Public Activities: see above for more details on such activities. Your public activities may appear on other websites, blogs, or feeds.
4. Other Information Collected Using Technology
Other information does not specifically identify you and are collected through technology. It includes tracking information collected by us as well as third parties.
We use various internet technologies to manage, and track the use of, the U of Digital Services. We use and disclose this information for any purpose, except where we are required to do otherwise under applicable law. Information that we collect using these technologies is combined with personal information about you. If we combine information with personal information, we will treat the combined information as personal information.
A) Device Information. We collect information about the computer, mobile device or other device you use to access the U of Digital Services, such as Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.
B) Cookies, Beacons, Local Storage and Other Similar Technologies. We may use “cookies,” Web beacons, tags and scripts, and other similar technologies including local storage objects. These technologies allow us to manage access to and use of the U of Digital Services, recognize you and provide personalization, and help us understand how people use the U fo Digital Services.
C) Analytics, Log Files and Reading History. As is true of most web sites, we gather certain information automatically and store it in log files. This information include IP address , browser type, operating system and other usage information about the use of the U of Digital Services, including a history of the pages you view.
We automatically combine this collected log information with other information we collect about you. We do this to improve services we offer you and to track access and use of the U of Digital Services across the devices that you use to access the U of Digital Services.
5. How Do I Opt Out From Receiving Emails?
You can choose not to receive commercial email messages or newsletters in the future by either (1) following the “unsubscribe” instructions located near the bottom of each email, or (2) you can email us at firstname.lastname@example.org.
6. Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose any sensitive personal information on or through the U of Digital Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.
7. Data Retention
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the U of Digital Services to you;
Whether there is a legal obligation to which we are subject; or
Whether retention is advisable in light of our legal position.
8. Is My Information Protected?
We seek to protect personal information with reasonable organizational, technological and physical safeguards commensurate to the sensitivity of the personal information. Although we take appropriate measures to safeguard your information, we cannot guarantee its absolute security. To further protect your data, we recommend that you use complex passwords for your accounts with us and for accounts with third parties that you link to any of your accounts with us. Please do not use the same passwords you use for U of Digital Services for other services or share your password with unauthorized people. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section above.
9. Children’s Guidelines
We do not knowingly collect or store any personal information from children except as permitted by applicable law.
10. International Transfers
U of Digital, LLC is headquartered in the United States. The information you provide to us or that we obtain as a result of your use of the U of Digital Services is collected in your country and subsequently transferred to the United States or to another country in which we have facilities or our affiliates operate or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.