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California Residents, please click here

Privacy Policy

Updated:  December 31, 2019

Effective starting: January 1, 2020

GenomeWeb and the associated newsletters, news alerts, data centers, research
reports, and other features are products of Crain Communications Inc. Our postal
address is 1 Battery Park Plaza, 8th Floor, New York, NY 10004.  We can be
reached by e-mail at customerservice@genomeweb.com or by telephone at
+1-212-269-4747. 

 

What this Privacy Policy covers

This Privacy Policy covers the information we collect about you when you use our
products or services, or otherwise interact with us (for example, by registering
for and receiving any of our print publications, digital e-mails and
newsletters; accessing our website; enrolling in any of our membership products;
attending our events, conferences, and webinars; downloading of Crain and
sponsor research and content; viewing our video, podcasts, and other content;
and using our mobile and digital applications and social media channels
(collectively, we refer to all of these products as Crain’s or our “Products” in
this Privacy Policy), unless a different policy is displayed. Unless otherwise
noted, our Products are provided by Crain in the United States and by Crain
Communications Limited in the United Kingdom.   

This policy also explains your choices about how we use information about you. 
Your choices include how you can modify your marketing preferences, object to
certain uses of information about you and how you can access and update certain
information about you.  

If you do not agree with this policy, do not access or use our Products or
interact with any other aspect of our business.  

This policy is intended to help you understand:

 * What information we collect about you
 * How we use information we collect 
 * How we share information we collect 
 * How we store and secure information we collect 
 * How to access and control your information 
 * How we transfer information we collect internationally 
 * Other important privacy information

Where we provide the Products under contract with an organization (for example
your employer) that organization controls the information processed by the
Products. For more information, please see Notice to End Users below. 

What information we collect about you

We collect information about you when you provide it to us, when you use our
Products, and when other sources provide it to us, as further described below.  

Information you provide to us

We collect information about you when you input it into the Products or
otherwise provide it directly to us.    

Account and Profile Information: We collect information about you when you
register for an account, create or modify your profile, set preferences, sign-up
for or make purchases through the Products. For example, you provide your
contact information and, in some cases, billing information when you register
for the Products. You also have the option of adding a display name, job title,
industry, and other details to your profile information to be displayed in our
Products.  We keep track of your preferences when you select settings within the
Products.

Content you provide through our websites: The Products also include our websites
owned or operated by us. We collect other content that you submit to these
websites, which include social media or social networking pages operated by us.
For example, you provide content to us when you provide comments or feedback or
when you participate in any interactive features, surveys, contests, promotions,
sweepstakes, activities or events.  

Information you provide through our support channels: The Products also include
our customer support, where you may choose to submit information regarding a
problem you are experiencing with a Product.  Whether you speak to one of
our representatives directly or otherwise engage with our support team, you will
be asked to provide contact information, a summary of the problem you are
experiencing, and any other documentation, screenshots or information that would
be helpful in resolving the issue.

Payment Information:  We collect certain payment and billing information when
you register for certain paid Products.  You might also provide payment
information, such as payment card details, which we collect via secure payment
processing services.

Information we collect automatically when you use the Products

We collect information about you when you use our Products, including browsing
our websites and taking certain actions within the Products.          

Your use of the Products: We keep track of certain information about you when
you visit and interact with any of our Products. This information includes the
features you use; the links you click on; the content you download from the
Products; and how you interact with others on the Products.  

Device and Connection Information: We collect information about your computer,
phone, tablet, or other devices you use to access the Products. This device
information includes your connection type and settings when you install, access,
update, or use our Products. We also collect information through your device
about your operating system, browser type, IP address, URLs of referring/exit
pages, and device identifiers. We use your IP address and/or country preference
in order to approximate your location to provide you with a better
experience.  How much of this information we collect depends on the type and
settings of the device you use to access the Products.  Server and data center
service administrators can disable collection of this information via the
settings or prevent this information from being shared with us by blocking
transmission at the local network level.   

Cookies and Other Tracking Technologies: 

What types of technologies do we use?

We use cookies, web beacons and other technologies to improve and customize our
Products and your experience; to allow you to access and use the
Products without re-entering your username or password; to understand usage of
our Products and the interests of our customers; to determine whether an email
has been opened and acted upon; and to present you with advertising relevant to
your interests. For each visitor to Crain’s Products, our servers may
automatically attempt to identify the user through a cookie set within your
browser. This is done to provide applicable access to the Crain’s Products. From
time to time we may also track information, in aggregate, on pages and features
that users access or view. The activity is collected and stored in our server's
log files. We may log Internet Protocol (IP) addresses, or the location of your
computer on the Internet required for systems administration and troubleshooting
purposes.

How do we use them?

 * Where strictly necessary.  These cookies and other technologies are essential
   in order to enable the Products to provide the feature you have requested,
   such as remembering you have logged in.
 * For functionality.  These cookies and similar technologies remember choices
   you make such as language or search parameters. We use these cookies to
   provide you with an experience more appropriate with your selections and to
   make your use of the Products more tailored.
 * For performance and analytics.  These cookies and similar
   technologies collect information on how users interact with the Products and
   enable us to improve how the Products operate. 
 * Targeting Cookies or Advertising Cookies.  These cookies collect information
   about your browsing habits in order to make advertising relevant to you and
   your interests. They remember the websites you have visited and that
   information is shared with other parties such as advertising technology
   service providers and advertisers.
 * Social media cookies.These cookies are used when you share information using
   a social media sharing button or “like” button on our websites or you link
   your account or engage with our content on or through a social media site.
   The social network and related service providers will record that you have
   done this. This information may be used for targeting/advertising activities.

How can you opt-out?

To opt-out of our use of cookies, you can instruct your browser, by changing its
options, to stop accepting cookies or to prompt you before accepting a cookie
from websites you visit. If you do not accept cookies, however, you may not be
able to use all aspects of our Products.  We and our third-party partners also
collect information using web beacons (also known as "tracking pixels").

Many browsers include their own management tools for removing local storage
objects and to manage "flash cookies". You may be able to opt out of receiving
personalized advertisements as described below under "Your Choices."

You will not be able to opt-out of any cookies or other technologies that are
“strictly necessary” for the Products.

Information we receive from other sources

We receive information about you from other users, from third-party services,
from our related companies, and from our business and channel partners.    

Other users of the Products: Other users of our Products may provide information
about you when they submit content through the Products.  We also receive your
email address from other users when they provide it in order to forward you an
article or to invite you to the Products.  Similarly, your employer may provide
your contact information when they designate you as a recipient of the
Products. 

Other services you link to your account: We receive information about you when
you or your administrator integrate or link a third-party service with our
Products.  For example, if you create an account or log into the Products using
your Facebook or Google credentials, we receive your name and email address as
permitted by your Facebook Google profile settings in order to authenticate you.
You or your employer may also integrate our Products with other services you
use, such as to allow you to access, store, share and edit certain content from
a third-party through our Products.  The information we receive when you link or
integrate our Products with a third-party service depends on the settings,
permissions and privacy policy controlled by that third-party service. You
should always check the privacy settings and notices in these third-party
services to understand what data may be disclosed to us or shared with our
Products.

Crain Companies:  We receive information about you from companies that are owned
or operated by Crain, in accordance with their terms and policies.

Crain Partners:  We work with global partners who provide consulting,
implementation, training and other services around our products.  Some of these
partners also help us to market and promote our products, generate leads for us,
and resell our products.  We receive information from these partners, such as
billing information, billing and technical contact information, company name,
what Crain products you have purchased or may be interested in, evaluation
information you have provided, what events you have attended, and what country
you are in. 

Other Partners: We receive information about you and your activities on and off
the Products from third-party partners, such as advertising and market research
partners who provide us with information about your interest in and engagement
with, our Products and online advertisements.   

How we use information we collect

How we use the information we collect depends in part on which Products you use,
how you use them, and any preferences you have communicated to us.  Below are
the specific purposes for which we use the information we collect about you.

To provide the Products and personalize your experience: We use information
about you to provide the Products to you, including to process transactions with
you, authenticate you when you log in, provide customer support, and operate and
maintain the Products.  For example, we use the name and picture you provide in
your account to identify you to tailor features that personalize your experience
and provide notifications and recommendations that are most relevant for you. 
For example, we may use your stated job title and activity to provide
information we think are relevant to your job function. We may use your email
domain to infer your affiliation with a particular organization or industry to
personalize the content and experience you receive on our websites. Where
you use multiple Products, we combine information about you and your activities
to provide an integrated experience, such as to allow you to find information
from one Product while searching from another or to present relevant product
information as you travel across our websites.   

For research and development:  We are always looking for ways to make our
Products more useful, relevant, faster, and secure to you.  We use collective
learnings about how people use our Products and feedback provided directly to
us to troubleshoot and to identify trends, usage, activity patterns and areas
for integration and improvement of the Products.   We automatically analyze and
aggregate frequently viewed articles to improve relevance of suggested topics
that auto-populate when you use the search feature.  In some cases, we apply
these learnings across our Products to improve and develop similar features or
to better integrate the services you use. We also test and analyze certain new
features with some users before rolling the feature out to all users.  

To communicate with you about the Products: We use your contact information to
send transactional communications via email and within the Products, including
confirming your purchases, reminding you of subscription expirations, responding
to your comments, questions and requests, providing customer support, and
sending you technical notices, updates, security alerts, and administrative
messages.  We also provide tailored communications based on your activity and
interactions with us.  For example, certain actions you take in the Products may
automatically provide you with the requested content.  These communications are
part of the Products and in most cases you can opt out of them.  If an opt out
is available, you will find that option within the communication itself or in
your account settings.   

To market, promote and drive engagement with the Products: We use your contact
information and information about how you use the Products to send promotional
communications that may be of specific interest to you, including by email and
by displaying Crain Product ads on other companies' websites and applications,
as well as on other companies’ platforms and websites.  These communications
are aimed at driving engagement and maximizing what you get out of the Products,
including information about new features, survey requests, newsletters, and
events we think may be of interest to you.  We also communicate with you about
new product offers, promotions and contests.  You can control whether you
receive these communications as described below under "Opt-out of
communications."

Customer support: We use your information to resolve technical issues you
encounter, to respond to your requests for assistance, to analyze crash
information, and to repair and improve the Products.

For safety and security: We use information about you and your use to verify
accounts and activity, to monitor suspicious or fraudulent activity and to
identify violations of Terms of Conditions of use policies. 

To protect our legitimate business interests and legal rights: Where required by
law or where we believe it is necessary to protect our legal rights, interests
and the interests of others, we use information about you in connection with
legal claims, compliance, regulatory, and audit functions, and disclosures in
connection with the acquisition, merger or sale of a business.  

With your consent: We use information about you where you have given us consent
to do so for a specific purpose not listed above.  

Legal basis for processing (for EEA users): 

If you are an individual in the European Economic Area (EEA), we collect and
process information about you only where we have legal basis for doing so under
applicable EU laws.  The legal basis depend on the Products you use and how you
use them. This means we collect and use your information only where:

 * We need it to provide you the Products, including to operate the Products,
   provide customer support and personalized features and to protect the safety
   and security of the Products;
 * It satisfies a legitimate interest (which is not overridden by your data
   protection interests), such as to market and promote the Products, for
   research and development and to protect our legal rights and interests;
 * You give us consent to do so for a specific purpose; or
 * We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific
purpose, you have the right to change your mind at any time, but this will not
affect any processing that has already taken place.  Where we are using your
information because we or a third-party (e.g. your employer) have a legitimate
interest to do so, you have the right to object to that use though, in some
cases, this may mean you no longer will have access to the Product.

How we share information we collect

We share information we collect about you in the ways discussed below, including
in connection with possible business transfers.

Sharing with other users 

When you use the Products, we share certain information about you with other
users.

For collaboration: You can create content, which may contain information about
you, for other users to see.  For example, when you comment, we display your
profile picture and name next to your comments so that other users with access
to the page or issue understand who made the comment.  

Managed accounts: If you register or access the Products using an email address
with a domain that is owned by your employer or organization, and such
organization requests, certain information about you including your name,
contact info, content and past use of your account may become accessible to that
organization’s administrator.  If you are an administrator for a particular site
or group of users within the Products, we may share your contact information
with current or past users, for the purpose of facilitating service-related
requests.  

Community Forums:  Our websites may offer publicly accessible comment areas and
blogs. You should be aware that any information you provide on these websites -
including profile information associated with the account you use to post the
information - may be read, collected, and used by any member of the public who
accesses these websites.  Your posts and certain profile information may remain
even after you terminate your account. We urge you to consider the sensitivity
of any information you input into these Products. To request removal of your
information from publicly accessible websites operated by us, please contact us
as provided below. In some cases, we may not be able to remove your information,
in which case we will let you know if we are unable to do so and why.

Sharing with third parties

We share information with third parties that help us operate, provide, improve,
integrate, customize, support and market our Products.

Service Providers: We work with third-party service providers to provide website
and application development, hosting, maintenance, backup, storage, virtual
infrastructure, payment processing, analysis and other services for us, which
may require them to access or use information about you.  If a service provider
needs to access information about you to perform services on our behalf, they do
so under close instruction from us, including policies and procedures designed
to protect your information.

Crain Partners: We work with third parties who provide consulting, sales, and
technical services to deliver and implement customer solutions around the
Products. We may share your information with these third parties in connection
with their services, such as to assist with billing and collections, to provide
localized support, and to provide customizations.  We may also share information
with these third parties where you have agreed to that sharing.

Links to Third-party Sites: The Products may include links that direct you to
other websites or services whose privacy practices may differ from ours. If you
submit information to any of those third-party sites, your information is
governed by their privacy policies, not this one. We encourage you to carefully
read the privacy policy of any website you visit.

Third-Party Widgets: Some of our Products contain widgets and social media
features, such as the Twitter "tweet" button. These widgets and features collect
your IP address, which page you are visiting on the Products, and may set a
cookie to enable the feature to function properly. Widgets and social media
features are either hosted by a third-party or hosted directly on our Products.
Your interactions with these features are governed by the privacy policy of the
company providing it.

With your consent: We share information about you with third parties when you
give us consent or we are allowed to do so under applicable laws.  

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our
Rights: In exceptional circumstances, we may share information about you with a
third-party if we believe that sharing is reasonably necessary to (a) comply
with any applicable laws, legal process or governmental request, (b) enforce our
agreements, policies and terms of service, (c) protect the security or integrity
of our products and services, (d) protect Crain, our customers or the public
from harm or illegal activities, or (e) respond to an emergency which we believe
in good faith requires us to disclose information to assist in preventing the
death or serious bodily injury of any person. 

Sharing with affiliated companies

We share information we collect with affiliated companies and, in some cases,
with prospective affiliates.  Affiliated companies are companies owned or
operated by us.  The protections of this privacy policy apply to the information
we share in these circumstances.

Business Transfers: We may share or transfer information we collect under this
privacy policy in connection with any merger, sale of company assets, financing,
or acquisition of all or a portion of our business to another company. You will
be notified via email and/or a general notice on the Products if a transaction
takes place, as well as any choices you may have regarding your information.

How we store and secure information we collect

Information storage and security

We use data hosting service providers in the United States, UK and Denmark to
host the information we collect, and we use technical measures to secure your
data.  While we implement safeguards designed to protect your information, no
security system is impenetrable and due to the inherent nature of the
Internet, we cannot guarantee that data, during transmission through the
Internet or while stored on our systems or otherwise in our
care, is absolutely safe from intrusion by others. Please refer to the Section
below titled “How we transfer information we collect internationally” for
information on the transfer of EU citizen’s data outside of the EU.

How long we keep information

How long we keep information we collect about you depends on the type of
information, as described in further detail below.  After such time, we will
either delete or anonymize your information or, if this is not possible (for
example, because the information has been stored in backup archives), then we
will securely store your information and isolate it from any further use until
deletion is possible.  

Account information: We retain your account information for as long as your
account is active and a reasonable period thereafter in case you decide to
re-activate the Products.  We also retain some of your information as necessary
to comply with our legal obligations, to resolve disputes, to enforce our
agreements, to support business operations, and to continue to develop and
improve our Products. 

Managed accounts: If the Products are made available to you through an
organization (e.g., your employer), we retain your information as long as
required by your employer.  For more information, see "Managed accounts and
administrators" above.

Marketing information: If you have elected to receive marketing emails from us,
we retain information about your marketing preferences for a reasonable period
of time from the date you last expressed interest in our Products, such as when
you last opened an email from us or ceased using your Crain account.  We retain
information derived from cookies and other tracking technologies for a
reasonable period of time from the date such information was created.   

How to access and control your information

You have certain choices available to you when it comes to your information.
Below is a summary of those choices, how to exercise them and any limitations.

Your Choices: 

You have the right to request a copy of your information, to object to our use
of your information (including for marketing purposes), to request the deletion
or restriction of your information, or to request your information in a
structured, electronic format.  Below, we describe the tools and processes for
making these requests.  You can exercise some of the choices by logging into the
Products and using settings available within the Products or your account. Where
the Products are administered for you by an employer (see "Notice to End Users"
below), you may first need to contact your employer to assist with your
request.  For all other requests, you may contact us as provided in the Contact
Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if
fulfilling your request would reveal information about another person, or if you
ask to delete information which we or your administrator are permitted by law or
have compelling legitimate interests to keep.  If you have unresolved concerns,
you may have the right to complain to a data protection authority in the country
where you live, where you work or where you feel your rights were infringed.

Access and update your information: Our Products give you the ability to access
and update certain information about you from within the Product. For example,
you can access your profile information from your account.  You can update your
profile information within your profile settings and modify content that
contains information about you using the editing tools associated with that
content.  

Deactivate your account:  If you no longer wish to use our Products, you or your
employer may be able to deactivate your account. If you can deactivate your own
account, that setting is available to you in your account settings. Otherwise,
please contact your employer. Please be aware that deactivating your account
does not delete your information.  

Delete your information: In some cases, you may ask us to delete accessing,
storing, using and otherwise processing your information.  You request by
contacting customer service. Please note, however, that we may need to retain
certain information for record keeping purposes, to complete transactions or to
comply with our legal obligations.   

Request that we stop using your information:  In some cases, you may ask us to
stop accessing, storing, using and otherwise processing your information where
you believe we don't have the appropriate rights to do so.  For example, if you
believe an account was created for you without your permission or you are no
longer an active user, you can request that we delete your account as provided
in this policy.  Where you gave us consent to use your information for a limited
purpose, you can contact us to withdraw that consent, but this will not affect
any processing that has already taken place at the time. You can also opt-out of
our use of your information for marketing purposes by contacting us, as provided
below.  When you make such requests, we may need time to investigate and
facilitate your request.  If there is delay or dispute as to whether we have the
right to continue using your information, we will restrict any further use of
your information until the request is honored or the dispute is resolved,
provided your employer does not object (where applicable).  

Opt out of communications: You may opt out of receiving promotional
communications from us by using the unsubscribe link within each email, updating
your email preferences within your Product account settings menu, or by
contacting us as provided below to have your contact information removed from
our promotional email list or registration database.  Even after you opt out
from receiving promotional messages from us, you will continue to receive
transactional messages (such as a receipt for a purchase) from us regarding
our Products.

You may be able to opt out of receiving personalized advertisements from other
companies who are members of the Network Advertising Initiative or who subscribe
to the Digital Advertising Alliance's Self-Regulatory Principles for Online
Behavioral Advertising. For more information about this practice and to
understand your options, please
visit: http://www.aboutads.info, http://optout.networkadvertising.org/ and http://www.youronlinechoices.eu.

Mobile Consents/Opt-Outs.We may send you messages, including marketing, via your
wireless email address or by short message service (SMS), wireless access
protocol (WAP) services or mobile phone service. By providing us with your
wireless email address or by signing up for any SMS, WAP or mobile phone
service, you consent to receiving services and messages at the address or number
you provide for such purposes, and understand that your wireless carrier’s rates
apply to these services/messages. You may opt-out of SMS, WAP or mobile services
by following the instructions provided in the message.

Send "Do Not Track" Signals: Some browsers have incorporated "Do Not Track"
(DNT) features that can send a signal to the websites you visit indicating you
do not wish to be tracked. Because there is not yet a common understanding of
how to interpret the DNT signal, our Products do not currently respond to
browser DNT signals. You can use the range of other tools we provide to control
data collection and use, including the ability to opt out of receiving marketing
from us as described above.

Data portability: Data portability is the ability to obtain some of your
information in a format you can move from one service provider to another (for
instance, when you transfer your mobile phone number to another carrier). 
Depending on the context, this applies to some of your information, but not to
all of your information.  Should you request it, we will provide you with an
electronic file of your basic account information.  

How we transfer information we collect internationally 

International transfers of information we collect

We collect information globally and primarily store that information in the
United States, the UK and Denmark. We transfer, process and store your
information outside of your country of residence, to wherever we or our
third-party service providers operate for the purpose of providing you the
Products.  Whenever we transfer your information, we take steps to protect it.  

International transfers within the Crain Companies: To facilitate our global
operations, we transfer EU data information to the United States and allow
access to that information from countries in which the Crain owned or operated
companies have operations for the purposes described in this policy. These
countries may not have equivalent privacy and data protection laws to the laws
of many of the countries where our customers and users are based. When we share
information about you within and among Crain corporate affiliates, we make use
of standard contractual data protection clauses, which have been approved by the
European Commission.

International transfers to third parties: Some of the third parties described in
this privacy policy, which provide services to us under contract, are based
in other countries that may not have equivalent privacy and data protection laws
to the country in which you reside. When we share information of customers in
the European Economic Area or Switzerland, we make use of the European
Commission-approved standard contractual data protection clauses, or other
appropriate legal mechanisms to safeguard the transfer. 

Other important privacy information

California Residents.

Under California law, California resident users may opt-out of the disclosure of
personal information to third parties for the third parties’ direct marketing
purposes.  You may contact us for such information or to opt-out of the sharing
of your personal information with third parties for marketing purposes as
detailed above at any time by sending an e-mail stating this preference and
including your full name and e-mail address to customerservice@genomeweb.comor
call +1-212-269-4747.  

Notice to End Usersc

Some of our products are provided to you for use by organizations, such as your
employer. Where the Products are made available to you through an organization,
that organization is the administrator of the Products and is responsible for
the accounts and/or Products over which it has control. If this is the case,
please direct your data privacy questions to your employer, as your use of the
Products is subject to that organization's policies. We are not responsible for
the privacy or security practices of an administrator's organization, which may
be different than this policy. 

Administrators may be able to: restrict, suspend or terminate your access to the
Products; access information in and about your account; and restrict your
ability to edit, restrict, modify or delete information. Please contact your
organization or refer to your administrator’s organizational policies for more
information.

Our policy towards children

The Products are not directed to individuals under 16. We do not knowingly
collect personal information from children under 16. If we become aware that a
child under 16 has provided us with personal information, we will take steps to
delete such information. If you become aware that a child has provided us with
personal information, please contact customer service.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy
policy changes on this page and, if the changes are significant, we will provide
a more prominent notice by adding a notice on the Products homepages, login
screens, or by sending you an email notification. We will also keep prior
versions of this Privacy Policy in an archive for your review.  We encourage you
to review our privacy policy whenever you use the Products to stay informed
about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop
using the Products and contact us at Customer Service if you wish to delete your
account(s), as outlined above.

Contact Us

Your information is controlled by Crain Communications Inc.  If you have
questions or concerns about how your information is handled, please direct your
inquiry to Crain Communications Inc, which we have appointed to be responsible
for facilitating such inquiries or, if you are a resident of the European
Economic Area, please contact our EU Representativex.

General Counsel
c/o Crain Communications Inc
1155 Gratiot Avenue
Detroit, MI  48207
E-Mail: privacyhelp@crain.com

313-446-6000

EU Representative:

Crain Communications Limited
c/o Crain Communications Inc
1155 Gratiot Avenue
Detroit, MI  48207
E-Mail: privacyhelp@crain.com

 

 

 

 

 

PRIVACY STATEMENT - CALIFORNIA 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information
contained in the Privacy Policy of Crain Communications Inc and its publications
(collectively, “we,” “us,” or “our”) and applies solely to subscribers, website
users, event attendees and others who reside in the State of California
(“consumers” or “you”). We adopt this notice to comply with the California
Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any
terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, is capable of
being associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer or device (“personal information”). In particular, we
have collected the following categories of personal information from consumers
within the last twelve (12) months:

table#data-collected { table-layout: fixed; margin: 2em 0; word-break: keep-all;
font-size: 0.875em; line-height: 1.5em; } table#data-collected td { border: 1px
solid black; border-spacing: 10px; padding: 10px; } table#data-collected td p {
margin: 0 !important; line-height: 1.5em; font-size: 0.875em; }

Category Examples Collected A. Identifiers.

A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,
Social Security number, driver's license number, passport number, or other
similar identifiers.

YES B. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature,
Social Security number, physical characteristics or description, address,
telephone number, passport number, driver's
license or state identification card number, insurance policy number, education,
employment, employment history, bank account number,
credit card number, debit card number, or any other financial information,
medical information, or health insurance information.
Some personal information included in this category may overlap with other
categories. YES C. Protected classification characteristics under California
 or federal law. Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status, medical condition,
physical or
mental disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic information (including
familial genetic information). YES D. Commercial information. Records of
personal property, products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies. YES E. Biometric
information. Genetic, physiological, behavioral, and biological characteristics,
or activity patterns used to extract a template or other identifier or
identifying information, such as, fingerprints, faceprints, and voiceprints,
iris or retina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data. NO F. Internet or other similar network
activity. Browsing history, search history, information on a consumer's
interaction with a website, application, or advertisement. YES G. Geolocation
data. Physical location or movements. NO H. Sensory data. Audio, electronic,
visual, thermal, olfactory, or similar information. NO I. Professional or
employment-related information. Current or past job history or performance
evaluations. YES J. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part
99)). Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records. NO K. Inferences
drawn from other personal information. Profile reflecting a person's
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes. YES

 

Personal information does not include:

 * Publicly available information from government records.
 * De-identified or aggregated consumer information.
 * Information excluded from the CCPA's scope, like:
   * health or medical information covered by the Health Insurance Portability
     and Accountability Act of 1996 (HIPAA) and the California Confidentiality
     of Medical Information Act (CMIA) or clinical trial data;
   * personal information covered by certain sector-specific privacy laws,
     including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act
     (GLBA) or California Financial Information Privacy Act (FIPA), and the
     Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following
categories of sources:

 * Directly and indirectly from our customers or their employers. For example,
   from information that our clients provide to us related to the services for
   which they engage us.
 * Directly and indirectly from activity on our websites. For example, from
   website usage details collected automatically.
 * From third parties that interact with us in connection with the services we
   perform.
 * Directly from third parties.

Use of Personal Information

We may use or disclose the personal information we collect in the manner
provided in our Privacy Policy, including but not limited to the following:

 * To provide you with information, products or services that you request from
   us. For example, we may use personal information to provide you with customer
   service, to process or fulfill orders and transactions, to verify customer
   information, to process payments, or to provide advertising or marketing
   services.
 * To improve our websites and present their contents to you. For example,
   debugging to identify and repair errors that impair existing intended
   functionality.
 * For testing, research, analysis and product development.
 * To provide you with email alerts, event registrations and other notices
   concerning our products or services, or events or news, that may be of
   interest to you.
 * Detecting security incidents, protecting against malicious, deceptive,
   fraudulent, or illegal activity, and prosecuting those responsible for that
   activity.
 * As described to you when collecting your personal information or as otherwise
   set forth in the CCPA.
 * To evaluate or conduct [certain business transactions] a merger, divestiture,
   restructuring, reorganization, dissolution, or other sale or transfer of some
   or all of our 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.

We will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party 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 use it for any purpose except
performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories
of personal information for a business purpose:

Category A:             Identifiers.

Category B:             California Customer Records personal information
categories.

Category C:             Protected classification characteristics under
California or federal law.

Category D:            Commercial information

Category F:             Internet or other similar network activity.

Category I:              Professional or employment-related information.
 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights
regarding their personal information. This section describes your CCPA rights
and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about
our collection and use of your personal information over the past 12 months.
Once we receive and verify your request, we will disclose to you:

 * The categories of personal information we collected about you.
 * The categories of sources of the personal information we collected about you.
 * Our business or commercial purpose for collecting or selling that personal
   information.
 * The categories of third parties with whom we share that personal information.
 * The specific pieces of personal information we collected about you (also
   called a data portability request).
 * If we sold or disclosed your personal information for a business purpose, two
   separate lists disclosing:
   * sales, identifying the personal information categories that each category
     of recipient purchased; and
   * disclosures for a business purpose, identifying the personal information
     categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information
that we collected from you and retained, subject to certain exceptions. Once we
receive and verify your request, we will delete (and direct our service
providers to delete) your personal information from our records, unless an
exception applies.

We may deny your deletion request if retaining the information is necessary for
us or our service providers to:

 1. Complete the transaction for which we collected the personal information,
    provide a product or service that you requested, take actions reasonably
    anticipated within the context of our ongoing business relationship with
    you, or otherwise perform our contract with you.
 2. Detect security incidents, protect against malicious, deceptive, fraudulent,
    or illegal activity, or prosecute those responsible for such activities.
 3. Debug products to identify and repair errors that impair existing intended
    functionality.
 4. Exercise free speech, ensure the right of another consumer to exercise their
    free speech rights, or exercise another right provided for by law.
 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal
    Code § 1546 seq.).
 6. Engage in public or peer-reviewed scientific, historical, or statistical
    research in the public interest that adheres to all other applicable ethics
    and privacy laws, when the information’s deletion may likely render
    impossible or seriously impair the research’s achievement, if you previously
    provided informed consent.
 7. Enable solely internal uses that are reasonably aligned with consumer
    expectations based on your relationship with us.
 8. Comply with a legal obligation.
 9. Make other internal and lawful uses of that information that are compatible
    with the context in which you provided it.

Exercising Your Privacy Rights

To exercise your privacy rights described above, please submit a request to us
by either filling out our Privacy Request Form (link below) or calling us at
1-877-860-9145.

You can submit a request to us to exercise the following privacy rights using
the link below, which will take you to a form: Right to Know, Right to Delete,
Shine the Light, and/or to submit a “Do Not Sell” request for any “sale” not
related to interest-based advertising.

SUBMIT PRIVACY REQUEST

Click this link to make a privacy
request:  http://cb.sailthru.com/join/6l2/privacy-request

For your protection, we will take steps to verify your identity before granting
access to your personal data or other information. For example, we may verify
your Privacy Request by matching information you provide with our records, or
you may be asked to log in to your online account (if applicable). We may
request additional information to verify your identity depending on the nature
of the Privacy Request and the sensitivity of the information sought. Only you
or a person registered with the California Secretary of State that you authorize
to act on your behalf may submit a Privacy Request to us. You may only submit a
Privacy Request twice within a 12-month period.

We cannot respond to your Privacy Request or provide you with personal
information if we cannot verify your identity or authority to make the request
and confirm that the personal information relates to you. Submitting a Privacy
Request does not require you to create an account with us. We will only use
personal information provided in a Privacy Request to verify the requestor’s
identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its
receipt. If we require more time (up to 90 days), we will inform you of the
reason and extension period in writing. Any disclosures we provide will only
cover the 12-month period preceding our receipt of your verifiable Privacy
Request. The response we provide will also explain the reasons we cannot comply
with a request, if applicable. For data portability requests, we will select a
format to provide your personal information that is readily useable and should
allow you to transmit the information from one entity to another entity without
hindrance.

We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:

 * Deny you goods or services.
 * Charge you different prices or rates for goods or services, including through
   granting discounts or other benefits, or imposing penalties.
 * Provide you a different level or quality of goods or services.
 * Suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services.

We may offer webinars, white papers, events and other programs free of charge in
exchange for your consent to share certain personal information, such as your
name and contact information, with selected business partners. You may opt in by
registering for one of these programs, but if you would like to register without
providing your personal information, please fill out the Privacy Request form
and you will be advised of the price difference.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any
time. When we make changes to this privacy notice, we will notify you through a
notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the
ways in which we collect and use your personal information, your choices and
rights regarding such use, or wish to exercise your rights under California law,
please do not hesitate to contact us at:

Phone: 1-877-860-9145
Website: crain.com
Email: privacyhelp@crain.com

Postal Address: Crain Communications Inc
Attn: Legal Department
1155 Gratiot Avenue
Detroit, MI 48207

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