Hotspex Media Inc. provides programmatic support, consulting, campaign management services, and facilitates and manages access to third-party services (our “Services“). We may receive, access or otherwise process personal information in order to provide our Services (the “Client Data”) to clients. Hotspex Media Inc. will only process Client Data on behalf of – and under the instructions of – our clients, as set out in our client agreements, or where otherwise required by applicable laws. Our Clients are the data controllers of their respective Client Data, and we are the data processor.
Information We Collect:
Information collected directly. We may collect personal information about you (such as your name, address, and contact details) directly from you. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, register for events we host or sponsor, register for an account, post comments on our Sites, or otherwise provide us information through the Sites. Generally, the information we collect includes your:
- Name, company name, and title/position.
- Email address, phone number, mailing address, and contact details.
- Other information related to your request or inquiry.
Purposes and Legal Bases of Use
We use the personal information you provide to respond to your request or inquiry and in the ordinary course of conducting our business, including as set out below:
- Providing Support and Services: to provide and operate our Sites, communicate with you about your use of the Sites, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
- Responding to Your Requests: to respond to your inquiries, fulfill your orders and requests, and consider your request or application (e.g., if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
- Analytics and Improvement: To better understand how users access and use the Sites, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
- Marketing: for direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
- Comply with Legal Obligations: To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
- General Business Operations: Where necessary to the administration of our general business, accounting, record keeping and legal functions.
Disclosures of Personal Information
We do not sell your personal information to third parties. In general, we disclose the personal information we collect as follows:
- Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, and customer service and support providers.
- Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
- Legally Required. We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, in response to a subpoena or court order).
- Protect our Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of us, our clients, and others.
- Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Cookies and Similar Devices
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using ourSite. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Services to, among other things, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
For more information about third-party ad networks and to opt out of interest-based ads from many ad networks go to:
· Canada: youradchoices.ca
· EU: youronlinechoices.eu
· U.S.: aboutads.info
Your Choices and Rights
Access, Amend andCorrect. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information, please send your request to firstname.lastname@example.org. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails or emailing email@example.com. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security.
Asa general rule, we retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant personal information of clients and Site visitors for at least three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our clients instruct us on how long to retain Client Data, which we handle as a data processor. We may retain personal data for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.