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PRIVACY AND COOKIE POLICY

Last updated on December 15, 2021


SmartBrief, a division of Future US LLC (“SmartBrief“,”we” or “us“) offers
industry-focused newsletter and content services in partnership with trade
associations, professional societies, nonprofits and corporations (in this
document we collectively refer to these organizations, our advertisers, social
media partners, service providers and certain other parties as our “Business
Partners“).

This privacy and cookie policy (“Policy”) describes how we collect, use and
share personal data through our “Services,” including in connection with our
email newsletters (the “Newsletters”), and when using this website (the
“Website”) and/or our mobile apps (the “App”).

If you have any questions about our privacy practices, please contact us at
privacy@smartbrief.com.


INFORMATION COLLECTION AND USE

We collect information about you in a range of forms, including personal data.
Personal data includes any information that, either alone or in combination with
other information held about you, identifies you as an individual, including,
for example, your name, postal address, email address and telephone number. We
collect and use your personal data to:

 * provide relevant, personalized, targeted news and information;
 * help target advertising messages, including in our email newsletters and
   other communications, so that we are able to continue providing our content
   to you at no cost;
 * operate, maintain, and improve our Services;
 * enable our customer service professionals to respond to your questions,
   concerns and feedback;
 * manage your subscriptions to our Services, including communicating with you
   about your subscriptions; and
 * send information, including technical notices, updates, security alerts, and
   support and administrative messages.

DATA WE COLLECT

Information You Provide Us. SmartBrief collects personal data, such as name,
email address, postal address, ZIP code and country, from each subscriber to our
Services. Personal data can be used to identify or contact you directly. We also
collect the name of your company, job title, level in organization, job
function, company type, company revenue and number of company employees. We
typically collect this information directly when you complete registration forms
or when you provide other information through our Website or via email. When we
collect this information directly, we let you know if providing the information
is optional or if it is required to provide our Services (for example, we must
have your email address to provide you with our email newsletter Services).

Information Provided to Us by Our Business Partners. We also collect personal
data indirectly when we receive it from our Business Partners. We may combine
information we have collected directly from you with information we obtain from
Business Partners or other companies.

When we obtain personal data from our Business Partners, that information will
be subject to the privacy policy of the Business Partner, which is different
from SmartBrief ’s policy. However, SmartBrief generally asks that Business
Partners have a relationship with you prior to sending us your information. For
example, for Business Partners that are trade associations, we generally ask
that they send us information only from persons who are affiliated with their
trade association, or persons whom they reasonably believe have an interest in
that trade association, and that they are complying with applicable laws with
respect to the information they send. From time to time, SmartBrief hosts
co-branded registration for some services provided by or in conjunction with our
Business Partners. In those cases, we generally ask that our Business Partners
adhere to the privacy principles listed here.

Nevertheless, we are not responsible for the privacy policies of our Business
Partners and strongly encourage you to visit the privacy policy of any website
prior to providing your information. Sometimes, we provide links to our privacy
policy and that of our Business Partner on the same webpage when information you
enter may be subject to both.

Information from Social Networking Sites. Our Services include an interface that
allows you to connect with social networking sites, for example, Facebook,
LinkedIn, Twitter, or Google+ (each an “SNS“). If you connect to an SNS through
our Services, you authorize us to access, use and store the information that you
agreed the SNS could provide to us based on your settings on that SNS. We will
access, use and store that information in accordance with this Policy. You can
revoke our access to the information you provide in this way at any time by
amending the appropriate settings from within your account settings on the
applicable SNS. We also may enable you to post content to SNSs. You acknowledge
and agree that you are solely responsible for your use of the SNSs and that it
is your responsibility to review the terms of use and privacy policy of the
third-party provider of such SNSs. We will not be responsible or liable for the
availability or accuracy of such SNSs, the content, products or Services on or
availability of such SNSs, or your use of any such SNSs.

Information Automatically Collected. We automatically log information about you
and your computer or mobile device when you use our Services, including visiting
our Website, using one of our Apps, and reading our email newsletters.

For example, when using our Services, we log when you open an email from us,
what links in our emails that you select, your IP address, your computer or
mobile device operating system name and version, manufacturer and model, browser
and email client type, internet browsing and usage habits, your internet service
provider, browser language, pages you viewed, how long you spent on a page,
access times, the website that referred you to our Services, and information
about your use of and actions on our Website. We collect this information about
you using cookies (see ’Cookies’ section) and pixel tags (see ’Pixel Tags’
section).

This data generally are used to help us administer our Services, to improve our
product offerings and in other ways set forth in this privacy policy.


COOKIES

Cookies are small data files stored on the hard drive of your computer or mobile
device by a website. Session cookies are generally used to aid navigation on our
Website, while persistent cookies allow us to maintain information between
visits, such as the number of site visits, and user preferences, such as your
username. A persistent cookie remains on your hard drive for a limited time
period, after which it expires and is deleted by your browser. For more
information about cookies, please visit http://www.allaboutcookies.org/cookies/.

COOKIES WE USE

We use the following types of cookies for the purposes set out below:

Essential Cookies. These cookies are essential to provide you with our Services
and to enable you to use some of the features of our Services. Without these
cookies, the Services cannot be provided, and we only use these cookies to
provide you with the Services.

Functionality Cookies. These cookies allow our Website to remember choices you
make when you use our Website. The purpose of these cookies is to provide you
with a more personal experience and to avoid you having to re-enter your
preferences every time you visit our Website.

Analytics and Performance Cookies. These cookies are used to collect information
about traffic to our Website and how users use our Website. The information
gathered does not identify any individual visitor. The information is aggregated
and anonymous. In addition, our measurement partners (including Google
Analytics) use cookies on our Services to help advertisers understand the
effectiveness of their advertising campaigns and to compare the performance of
those campaigns to ads displayed on other websites and apps.

Advertising & Targeting Cookies. These cookies track your browsing habits to
enable us to show advertising that is more likely to be of interest to you, both
on and off our Services and to measure the effectiveness and reach of ads and
services. These cookies use information about the industries you are interested
in and your browsing history to group you with other users who have similar
interests. Based on that information, and with our permission, third-party
advertisers can place cookies to enable them to show advertisements that we
think will be relevant to your interests while you are on third-party websites.

Social Media Cookies. These cookies are used when you share information using a
social media sharing button or “like” button on our Website or you link your
account or engage with our content on or through a social networking website
such as Facebook, Twitter, LinkedIn or Google+. The social network will record
that you have done this.

DISABLING COOKIES

You can typically remove or reject cookies via your browser settings. To do
this, follow the instructions provided by your browser (usually located within
the “settings”, “help”, “tools” or “edit” menus). Many browsers are set to
accept cookies until you change your settings.

If you reject the cookies, you still may use our Services. However, please note
that if you disable cookies, the functionality offered by the Services may be
limited as a result.

PIXEL TAGS

We may use pixel tags (also known as web beacons and clear GIFs) on our Services
to track the actions of users on our Services. A pixel tag is a tiny, opaque
graphic image, usually no larger than 1 pixel x 1 pixel, which is placed on a
website or in an email that is used to monitor the behavior of the user. Pixel
tags measure how relevant our newsletter content is to our subscribers, measure
the success of our marketing campaigns, and compile statistics about usage of
the Services, so that we can manage our content more effectively and provide our
readers with more useful content.


INFORMATION SHARING AND DISCLOSURE

We may share your personal data and other types of data as follows:

Business Partners. Periodically, we may share information, including personal
data, collected from you with trade associations and other Business Partners
with whom we do business. For example, if you subscribe to a SmartBrief
newsletter service sponsored by a trade association, we may provide your
information to that trade association, including your name, email address,
postal address, company and title. That trade association may contact you or
invite you to participate in other association activities. This may also include
sharing opt-out lists of customers who do not wish to receive marketing, with
our Business Partners.We also share de-identified information and/or aggregated
information with our Business Partners.

Advertisers and Advertising Networks. We do not share personal data with
advertisers, except in accordance with this policy and where you have given us
permission to do so. For example, you may give us permission to share your
personal data with a third party in connection with an advertiser’s lead
generation campaign. We may also pre-fill a lead generation form with your
personal data for you to submit directly to one of our advertisers. We also
share de-identified information and/or aggregated information with our
advertisers.

We work with third party advertising networks who use cookies, tags and similar
technologies for the delivery of advertising. These advertisements are delivered
by advertising networks and may be targeted based on your geographic area and
activity. We may share de-identified information and/or aggregated information
about our subscribers for use by third-parties, including but not limited to,
targeting, look-alike modeling, and campaign measurement.

Social Networking Sites. We share de-identified information with our social
media partners,to enable them to show advertisingthat is more likely to be of
interest to you.

Third Parties. If you supply information directly to SmartBrief, a Business
Partner or an advertiser via a registration form in the Service (including our
Website and Apps) as part of a promotion, advertiser lead-generation campaign,
contest, third-party subscription or similar activity, we may supply both
personal data and anonymous data you provide directly to our Business Partner
and/or advertiser. In addition, when you provide such information, we may retain
this information and use it to augment your subscriber profile for our records
and possible later use as provided in this Policy. If SmartBrief, a Business
Partner or an advertiser is conducting a promotion or campaign on our Website or
App in which your information will be collected by SmartBrief and shared in ways
other than as set forth in this Policy, we will disclose such sharing prior to
the transfer and you will be given the opportunity to request that your
information not be shared. In some cases, you may not be able to participate in
a particular promotion or campaign if you have chosen not to share personal
data. SMARTBRIEF MAY PROVIDE YOUR PERSONALLY IDENTIFIABLE INFORMATION TO A
THIRD-PARTY COMPANY WITH YOUR CONSENT. BECAUSE WE DO NOT CONTROL THE PRIVACY
PRACTICES OF THESE THIRD-PARTY COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR
PRIVACY POLICIES.

AGGREGATED DATA

We also aggregate information about our subscribers and the ways they use our
Services. This information does not identify you personally. We use this
information for market research purposes and to improve the quality of the
Services we offer. We reserve the right to disclose aggregated, anonymous data
we have collected to third parties for any purpose.

Third-Party Service Providers. Except in accordance with this policy, SmartBrief
does not rent, sell or share your personal data with nonaffiliated third parties
without your consent. SmartBrief may, however, share personal data with trusted
third-party service providers and contractors. These third-party service
providers and contractors are prohibited from using the information for purposes
other than performing services for SmartBrief. A list of our service providers
can be found at http://smartbrief.com/privacy/data-processors.

Corporate Restructuring. SmartBrief may transfer information, including any
personal data, to a successor entity in connection with a corporate merger,
consolidation, sale of assets, bankruptcy, or other corporate change. If
SmartBrief is involved in a merger, acquisition or sale of all or a portion of
its assets, you will be notified via email and/or a prominent notice on our
Website of any change in ownership or uses of your information, as well as any
choices you may have regarding your personal data.

Other Disclosures. SmartBrief may disclose your information to third parties (a)
when obligated to do so by law, or in connection with a subpoena, court orders
or legal process, (b) to investigate, prevent, or take action regarding
suspected or actual prohibited activities, including but not limited to fraud
and situations involving potential threats to the physical safety of any person,
(c) to enforce our privacy policy, and (d) to protect our rights, privacy,
safety or property, and/or that of you or others. We reserve the right to
disclose aggregated, anonymous data we have collected to third parties for any
purpose.


LAWFUL BASIS FOR PROCESSING

If you are a citizen of the EEA, UK or Switzerland, in order to process your
personal data, we must have a lawful reason for doing so. GDPR sets out six
lawful bases under which organisations can collect, use and store personal data.
We rely on four of the lawful bases:

Necessary for the performance of a contract. If you are a subscriber of a
newsletter, for example, we will process your personal data on the basis that it
is necessary for us to provide our products and services to you.

Consent. In some instances we rely on your specific consent to process your
personal information. This is where you have actively agreed and ‘opted-in’, for
example; to receive newsletters and marketing communications from us, and you
have the right to withdraw your consent at any time.

Compliance with laws. We may have to process and share your personal data in
order to comply with our legal obligations, or to protect our rights or the
rights of others.

Legitimate interests. In some situations we rely on our legitimate business
interests in order to collect and use your personal data. In these situations,
we have conducted a balancing test to carefully consider the impact of the
processing on your interests, rights and freedoms. We will only undertake the
processing if we are satisfied there is no negative impact on you. We may rely
on Legitimate Interests for the following activities:

 * providing, maintaining, improving and developing our products and services;
 * sending direct marketing communications about our products and services to
   subscribers;
 * sending marketing communications related to the products and services of
   carefully selected companies in a business-to-business context;
 * managing suppression and unsubscribe requests;
 * researching publicly available business contact details;
 * analysing the use of our products and services;
 * using analytics to identify usage trends and determining the effectiveness of
   campaigns;
 * dealing with queries and complaints;
 * identifying fraudulent behaviour and ensuring our products and systems are
   secure.

If you object to our reliance on Legitimate Interests for any purpose please
contact our Data Protection Officer at privacy@smartbrief.com.


SECURITY

SmartBrief has security measures in place designed to protect the loss, misuse
and alteration of the information under our control. Our hardware infrastructure
is housed in a controlled access facility that restricts access to authorized
individuals with positive identification. The network infrastructure is
protected by a firewall and traffic is monitored and logged both on the firewall
and servers. Administrative access is limited not only to authorized employees
but also to specific remote administration protocols. All employees with access
to personal data are trained in SmartBrief’s security policies and practices.
SmartBrief will continue to conduct internal reviews of its security systems and
make all necessary enhancements to ensure the safety of the Website and its
users. No method of transmission over the Internet or method of electronic
storage is 100% secure; therefore, while SmartBrief strives to use commercially
acceptable means to protect your information, we cannot guarantee absolute
security.


CHILDREN’S PRIVACY

SmartBrief’s products and Services are designed for those ages 18 and older.
SmartBrief does not intentionally gather personal data from visitors who are
under the age of 13. If a child under 13 submits personal data to us and we
learn that the personal data is the information of a child under 13, SmartBrief
will delete the information as soon as reasonably practicable. If a parent or
guardian becomes aware that his or her child has provided us with information
without their consent, he or she should contact us at privacy@smartbrief.com.


ADVERTISING CHOICES AND SUBSCRIPTION PREFERENCES

SmartBrief collects data, including de-identified data, via our Services, and
via the websites of our Business Partners and other third parties, to help
tailor content and advertising. We also enable Business Partners, advertising
networks and other third parties to collect and/or use de-identified data from
our Services. Cookies and web beacons are typically used to help collect this
information. We support the industry self-regulation program established for
Online Behavioral Advertising (“OBA”). For more information about these
practices, and to learn about the choices available to you regarding how this
information is used, please visit www.AboutAds.info. The site provides you with
an option to opt out of some or all OBA as you prefer. Please note that
preferences are stored separately for each browser and device you use, so you
may have to repeat the opt-out process if you wish your preferences to apply
universally.

Each email sent through the SmartBrief system contains an easy, automated way
for you to stop receiving that newsletter. To unsubscribe, select the
“unsubscribe” link in the footer of an email from SmartBrief and follow the
directions to communicate your preferences to us. Alternatively, you may reply
to your SmartBrief email and type the word “UNSUBSCRIBE” in the subject line.

We also encourage you to participate in our referral program to share SmartBrief
with a friend or colleague. When you provide us with a referral’s email address,
we store this information for the sole purpose of sending the referral a
one-time email inviting that person to register on the Website. We will not send
newsletters or any additional emails until your referral has indicated to us
that they desire to receive such material..


YOUR RIGHTS

Under the General Data Protection Regulation (GDPR), you have a number of
important rights free of charge where products and/or services are delivered in
the European Economic Area. In summary, those include rights to:

 * fair processing of information and transparency over how we use your use
   personal information;
 * access to your personal information and to certain other supplementary
   information that this Privacy Policy is already designed to address;
 * require us to correct any mistakes in your information which we hold;
 * require the erasure of personal information concerning you in certain
   situations;
 * receive the personal information concerning you which you have provided to
   us, in a structured, commonly used and machine-readable format and have the
   right to transmit those data to a third party in certain situations;
 * object at any time to processing of personal information concerning you for
   direct marketing;
 * object to decisions being taken by automated means which produce legal
   effects concerning you or similarly significantly affect you;
 * object in certain other situations to our continued processing of your
   personal information; and
 * otherwise restrict our processing of your personal information in certain
   circumstances.

For further information on each of those rights, including the circumstances in
which they apply, see the Guidance from the UK Information Commissioner’s Office
(ICO) on individuals’ rights under GDPR.

If you wish to exercise any of these rights, please contact us at
privacy@smartbrief.com. In your request, please make clear: (i) what personal
data is concerned; and (ii) which of the above rights you would like to
exercise. For your protection, we may only implement requests with respect to
the personal data associated with the particular email address that you use to
send us your request, and we may need to verify your identity before
implementing your request. We will try to comply with your request as soon as
reasonably practicable and, in any event, within one month of your request.
Please note that we may need to retain certain information for recordkeeping
purposes and/or to complete any transactions that you began prior to requesting
such change or deletion.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information
from being accidentally lost, or used or accessed in an unauthorised way. We
limit access to your personal information to those who have a genuine business
need to know it. Those processing your information will do so only in an
authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security
breach. We will notify you and any applicable regulator of a suspected data
security breach where we are legally required to do so.


INTERNATIONAL DATA TRANSFER

We are headquartered in the United States and may use service providers that
operate in other countries. If we transfer your personal information from the
United Kingdom or European Economic Area to a country such that we are required
to apply additional safeguards to your personal information under European data
protection laws, we will do so. These steps include implementing the European
Commission’s Standard Contractual Clauses for transfers of personal information
to our service providers and business partners. To the extent applicable,
SmartBrief may rely on derogations as set forth in Article 49 of the GDPR for
the transfer and onward transfer of personal information collected from
individuals in Europe to the United States, and other countries that the EU
views as not providing adequate data protection. Specifically, we may transfer
such information to another party in accordance with our lawful basis for
processing. Please contact us for further information about any such transfers
or the specific safeguards applied.


DATA RETENTION

We will only retain your personal data as long as reasonably required for you to
use the Services, unless a longer retention period is required or permitted by
law (for example for regulatory purposes).


SENSITIVE PERSONAL DATA

Subject to the following paragraph, we ask that you not send us, and you not
disclose, any sensitive personal data (for example, social security numbers,
information related to racial or ethnic origin, political opinions, religion or
other beliefs, health, biometrics or genetic characteristics, criminal
background or trade union membership) on or through the Services or otherwise to
us.

If you send or disclose any sensitive personal data to us, you consent to our
processing and use of such sensitive personal data in accordance with this
privacy policy. If you do not consent to our processing and use of such
sensitive personal data, you must not submit such content.


HOW TO COMPLAIN

We are committed to resolving any complaints about our collection or use of your
personal data. If you would like to make a complaint regarding this privacy
policy or our practices in relation to your personal data, please contact us at
privacy@smartbrief.com. We will respond to your complaint as soon as we can and
in any event, within one month.

We hope to resolve any complaint brought to our attention, however, the General
Data Protection Regulation also gives you the right to lodge a complaint with a
supervisory authority, in particular in a European Economic Area state or in the
United Kingdom if you work, normally live or if any alleged infringement of data
protection laws occurred in the relevant state. The supervisory authority in the
UK is the Information Commissioner who may be contacted at
https://ico.org.uk/concerns/ or telephone: +44 (0)303 123 1113.


CHANGES TO THIS PRIVACY POLICY

This privacy policy is subject to change. If SmartBrief makes any substantive
changes to the way we use personal data or other data under our control, we will
post a clear and conspicuous notice that we have updated our privacy policy on
our Website and/or in our newsletter Service prior to the changes being made.


CONTACTING US

The data controller of your personal data is Future US LLC, 10th floor, 1100
13th Street, N.W Washington, DC 20005. For any questions you may have about our
Services or this Privacy and Cookie Policy, please email us at
privacy@smartbrief.com.


LEGAL INFORMATION

Copyright © 1999-2021 Future US LLC. All rights reserved. Protected by copyright
laws of the United States and international treaties. Reproduction, copying or
redistribution for commercial purposes is strictly prohibited without the
express written permission of SmartBrief. SmartBrief contains links to
third-party websites. The linked sites are not under the control of SmartBrief,
and SmartBrief is not responsible for the contents, advertising, products, or
any other materials or links contained in those linked sites. SmartBrief
provides these links only as a convenience, and inclusion of a link does not
imply endorsement of the linked site by SmartBrief, its Business Partners or its
affiliates. Information, documents, and links included in SmartBrief are
provided “as is” without any warranty. While SmartBrief uses reasonable efforts
to include accurate information, it does not make any representation as to its
accuracy or completeness. The material is available to users at their own risk
and SmartBrief is not liable for any damages arising from the use of the
SmartBrief products and Services.


NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

(AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM
HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR
HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT
WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR
THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS
MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A
CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD
PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS
WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED.
CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH
THIS LAW BY EMAILING privacy@smartbrief.com. PLEASE NOTE THAT WE ARE REQUIRED TO
RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED
TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS EMAIL ADDRESS.


IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only to California residents.  It describes how we collect,
use and share Personal Information of California residents in operating our
business, and their rights with respect to that Personal Information.  For
purposes of this section, “Personal Information” has the meaning given in the
California Consumer Privacy Act of 2018 (“CCPA”) but does not include
information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights
listed below. However, these rights are not absolute, and in certain cases we
may decline your request as permitted by law.

 * Information.  You can request the following information about how we have
   collected and used your Personal Information during the past 12 months: the
   categories of Personal Information that we have collected; the categories of
   sources from which we collected Personal Information; the business or
   commercial purpose for collecting and/or selling Personal Information; the
   categories of third parties with whom we share Personal Information; whether
   we have disclosed your Personal Information for a business purpose, and if
   so, the categories of Personal Information received by each category of third
   party recipient; or whether we’ve sold your Personal Information, and if so,
   the categories of Personal Information received by each category of third
   party recipient.
 * Access.  You can request a copy of the Personal Information that we have
   collected about you during the past 12 months.
 * Deletion.  You can ask us to delete the Personal Information that we have
   collected from you.
 * Opt-out of sales.  If we sell your Personal Information, you can opt-out.] 
   [In addition, if you direct us not to sell your Personal Information, we will
   consider it a request pursuant to California’s “Shine the Light” law to stop
   sharing your personal information covered by that law with third parties for
   their direct marketing purposes.
 * Opt-in.  If we know that you are younger than 16 years old, we will ask for
   your permission (or if you are younger than 13 years old, your parent’s or
   guardian’s permission) to sell your Personal Information before we do so.
 * Nondiscrimination.  You are entitled to exercise the rights described above
   free from discrimination. This means that we will not penalize you for
   exercising your rights by taking actions such as denying you services;
   increasing the price/rate of services; decreasing service quality; or
   suggesting that we may penalize you as described above for exercising your
   rights.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

 * Right to information, access and deletion. You can request to exercise your
   information, access and deletion rights by: visiting
   https://www2.smartbrief.com/subscribertools/login.jsp or emailing
   privacy@smartbrief.com
 * Right to opt-out of the “sale” of your Personal Information.  We do not sell
   your Personal Information in the conventional sense (i.e., for money). 
   However, like many companies, we use services that help deliver
   interest-based ads to you.  California law classifies our use of these
   services as a “sale” of your Personal Information to the companies that
   provide the services. This is because we allow them to collect information
   from our website users (e.g., online identifiers and browsing activity) so
   they can help serve ads more likely to interest you. You can request to
   opt-out out of this “sale” of your personal information here: Do Not Sell My
   Personal Information.

We will need to confirm your identity and California residency to process your
requests to exercise your information, access or deletion rights.  We cannot
process your request if you do not provide us with sufficient detail to allow us
to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by
reference to the statutory categories specified in the CCPA, and describes our
practices during the 12 months preceding the effective date of this Privacy
Policy. Categories in the chart refer to the categories described above in the
general section of this Privacy Policy.

 

 

Statutory category of personal information (PI) Source of the PI Purpose for
collection Categories of third parties to whom we “disclose” the PI for a
business purpose Categories of third parties to whom we “sell” the PI
Identifiers You, Public sources, Business partners, Our clients Service
delivery, Research & development, Marketing, Compliance & Operations Affiliates,
Advertising partners, Service-related third parties, Professional advisors,
Authorities and others, Business transferees Business Partners (for business and
commercial purposes as defined in the section above entitled Information Sharing
and Disclosure) Commercial Information You, Our client Service delivery,
Research & development, Marketing, Compliance & Operations Affiliates,
Service-related third parties, Professional advisors, Authorities and others,
Business transferees None Online Identifiers You, Our client Service delivery,
Research & development, Marketing, Compliance & Operations Affiliates,
Service-related third parties, Professional advisors, Authorities and others,
Business transferees Advertising partners (to facilitate online advertising),
Business Partners (for business and commercial purposes as defined in the
section above entitled Information Sharing and Disclosure) Internet or Network
Information You, Our client Service delivery, Research & development, Marketing,
Compliance & Operations Affiliates, Service-related third parties, Professional
advisors, Authorities and others, Business transferees Business Partners (for
business and commercial purposes as defined in the section above entitled
Information Sharing and Disclosure) Geolocation Data You, Public sources,
Business partners, Automatic collection, Our clients Service delivery, Research
& development, Marketing, Compliance & Operations Affiliates, Service-related
third parties, Professional advisors, Authorities and others, Business
transferees Business Partners (for business and commercial purposes as defined
in the section above entitled Information Sharing and Disclosure)

 

We describe: the sources from which we collect this information in the section
above entitled Information We Collect and Use; and the business and commercial
purposes for which we collect this information in the section above entitled
Information Sharing and Disclosure.

 

 

Glossary

 

Statutory category Definition (categories may overlap) What we collect
Commercial Information Records of personal property, products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendencies. Contact data, Identity data, Transaction data, Communications,
Marketing data Geolocation Data Precise location, e.g., derived from GPS
coordinates or telemetry data. Identifiers Real name, alias, postal address,
unique personal identifier, customer number, email address, account name, social
security number, driver’s license number, passport number, or other similar
identifiers. Contact data, Identity data, Data about others Inferences The
derivation of information, data, assumptions, or conclusions from any other
category of Personal Information to create a profile about a person reflecting
the person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities and aptitudes. May
be derived from your: Device data, Online activity data Internet or Network
Information Browsing history, search history, and information regarding a
person’s interaction with an Internet website, application, or advertisement.
Device data, Online activity data Online Identifiers An online identifier or
other persistent identifier that can be used to recognize a person, family or
device, over time and across different services, including but not limited to, a
device identifier; an Internet Protocol address; cookies, beacons, pixel tags,
mobile ad identifiers, or similar technology; customer number, unique pseudonym,
or user alias; telephone numbers, or other forms of persistent or probabilistic
identifiers (i.e., the identification of a person or a device to a degree of
certainty of more probable than not) that can be used to identify a particular
person or device. Device data, Identity data

 


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