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PRIVACY POLICY



Effective: January 1st, 2023




EBULLETINS ARE PUBLISHED BY DEMAND WORKS MEDIA LLC




IN BRIEF



DemandWorks Media and eBulletins are committed to privacy, data quality, and
highly relevant marketing communications that are valued by clients and leads
alike. DWM collects personal information about website visitors, subscribers to
our eBulletins newsletters, and individuals in their professional capacity
(collectively, “you”) to provide our services, which are identification of
individuals who may be interested in our clients’ products or services (i.e.,
lead generation) and providing email newsletters to individuals who sign up to
receive them through our eBulletins service. 

We disclose your personal information to our clients, which are companies that
wish to contact you with marketing communications that are relevant to you in
your professional capacity or your company. We may disclose your personal
information to our service providers who support our services. We may also
disclose your personal information to our partners who assist us with our own
online marketing activities. We make options available to you to opt-out of our
disclosures to our clients or partners. (But, please be aware that if you
opt-out, you may miss out on offers that are relevant to you in your
professional capacity or your company.) 

The privacy policy below is a detailed description of how we collect, use, and
disclose personal information, your rights with respect to your personal
information, and your opt-out options. 

To exercise rights that you may have under the law, please contact us
at privacy@demandworksmedia.com.


DEMANDWORKS MEDIA FULL PRIVACY POLICY



This Privacy Policy explains how DemandWorks Media LLC and eBulletins
(collectively, “DWM”) collects, uses, and shares information when you interact
with our websites, newsletters, social media sites and handles, and emails (our
“Sites”). This Policy is not a binding contract and does not create contractual
obligations. 

This Policy applies to DWM and our websites, social media sites and handles,
emails we send, and the information we collect when you interact with us. It
also applies anywhere it is linked. It does not apply to non-DWM websites and
mobile applications that may link to the Sites or be linked to or from the
Sites; please review the privacy policies on those websites and applications
directly to understand their privacy practices. 

We may make changes to this Policy from time to time. We will post any changes,
and such changes will become effective when they are posted. Your continued use
of our Sites following the posting of any changes will mean you accept those
changes.

If you have questions, contact us at:

DemandWorks Media
444 N. Michigan Avenue, Suite 1200
Chicago, IL 60611
(312) 204-7275

Email: privacy@demandworksmedia.com 


INFORMATION WE COLLECT



We collect information that you give us directly, that we capture automatically
when you use our Sites, and that we collect from third party sources. 

Information you give us: Our Sites enable you to, for example, give us contact
and payment information to register an account and buy and sell items, interact
with forums and chatrooms, post comments, or submit surveys. 

Information we collect automatically: When you interact with the Sites
(including when you interact with games that incorporate our software), certain
information about your use of our Sites is automatically collected. For example,
we track the status of items that you buy and sell, and we collect information
about the webpages you view and how you move through our website, how you
reached our website, how you interact with our social media pages, and how you
interact with our email communications.

Below is a list of our partners who collect information from you on our
websites.

Use  Analytics  Analytics  Analytics  Analytics  Personalized
Advertising  Personalized Advertising  Personalized Advertising  Personalized
Advertising  Social Media  

 Partner  Google/Google Tag
Manager  Ensighten  Drift  Hubspot  Google/Doubleclick  Tradedesk  Bluekai  AdRoll
Roundtrip  LinkedIn 

 

  Further Information  Google Privacy and Terms  Privacy Policy  Privacy
Policy  Privacy Policy  Google Privacy and Terms   Opt-out  Terms of
Use  Nextroll Privacy Notice  User Agreement
Ads Agreement
Additional Terms for Optional Features

Information from third party sources: We may collect information about you from
our clients and third party sources such as databases that maintain up-to-date
business contact information. We collect and use that information in accordance
with those sources’ privacy terms.

We also may combine information that we collect from different sources into a
single record.

The following is a comprehensive listing of the personal information we collect.

 * Personal Identifiers:
   * We collect your name, business phone number, business email address, and
     business contact address. If you choose to create an account, you will also
     be asked to create a username, and we will assign one or more unique
     identifiers to your profile. 
   * We collect your social media handle and basic account information when you
     interact with our Sites through social media.
   * We collect a unique numerical identifier, assigned to you by a cookie we
     deploy automatically when you use our Sites.
   * We or third parties operating on our behalf collect information about the
     device you use to access our Sites, such as your IP address, a device ID,
     and information about your web browser. 
 * Commercial Information: When you create an account, such as to receive
   eBulletins newsletters, we create records about that account. 
 * Internet or Other Electronic Network Activity Information: We collect
   information about your browsing history, search history, information
   regarding your interaction with websites and applications automatically when
   you use our Sites. 
 * Geolocation Data: We collect your IP address automatically when you use our
   Sites. We or third parties operating on our behalf may be able to determine
   your general location based on the IP address. 
 * Professional or employment-related information: We collect information about
   your current employer and your employment history. 
 * Education information: We collect information about the institutions you have
   attended and the level of education you have attained. 
 * Inferences drawn to create a profile about a consumer reflecting the
   consumer’s preferences or characteristics: We or third parties operating on
   our behalf may analyze your actual or likely preferences based on the
   information we gather about you as described above. 

We do not collect the following types of personal information:

 * Protected Classifications; Biometric Information; or Audio, electronic,
   visual, thermal, olfactory, or similar information.


HOW WE USE INFORMATION



We may use the information we collect from you for the following purposes:

Provide our services to our corporate clients and newsletter subscribers:

 * Generate leads.
 * Establish and administer your account.
 * Deliver newsletter content.
 * Authenticate access to your account.
 * Perform maintenance and operations, including management of the network and
   devices supporting the Sites and our systems.
 * Provide technical support and assure quality of customer service
   interactions.
 * Facilitate hardware and software upgrades for devices and systems.

Communicate with you:

 * Respond to your inquiries.
 * Personalize communications.
 * Send you service-related announcements.

Make improvements to our products and services:

 * Identify and develop new products and services.
 * Understand how our Sites are used.
 * Create measurement and analytics reports.

Provide recommendations and deliver relevant advertising:

 * Market our and our clients’ products and services.
 * Determine which content to recommend to you.
 * Send you promotional communications for the Sites and other products and
   services we think may be of interest to you.

Investigate theft or other illegal activities and ensure a secure online
environment: 

 * Detect the unauthorized reception, use, or abuse of the Service.
 * Protect you and other subscribers from fraudulent, abusive, unlawful use of,
   or subscription to, the Service.
 * Protect our rights, our personnel, and our property.
 * Comply with applicable law.

We and our partners use cookies, tags, pixels, web beacons, or other means of
collecting information automatically from you for the following purposes:

 * Site Operations/Essential Cookies: To enable features that are necessary for
   providing you the services on our site, such as identifying you as being
   signed in, tracking content views, and remembering your preferences.
 * Analytics: To allow us to understand how our services are being used, track
   site performance and make improvements.
 * Personalized Advertising: To deliver personalized advertising based on your
   preferences or interests and to measure the effectiveness of ads.
 * Social Media: To enable you to share content from our services through social
   networks.


HOW WE SHARE INFORMATION



With Service Providers: We may disclose personal information to our service
providers, which are companies that process personal data on our behalf. We may
disclose your personal information to them without your consent in order to
deliver the Service and conduct business activities. We require the service
providers to treat the information we disclose to them, or that they collect on
our behalf, as confidential and to use the information only for the purposes for
which they have been engaged. The following is a list of categories of our
service providers.

 * Billing and collection providers, such as payment processors and
   organizations that assist us in assessing your credit and payment status.
 * Auditing and accounting firms.
 * Professional services consultants, such as firms that assist with providing
   legal services, or supplying project-based resources and assistance.
 * Advertising, marketing, and analytics services, including entities that
   analyze the information we collect from or about you to communicate with and
   advertise to you. 
 * Security vendors, such as entities that assist with security incident
   verification and response, service notifications, and fraud prevention.
 * IT vendors, such as entities that assist with website design, hosting, and
   maintenance, data and software storage, and network operation.

There are limited circumstances in which the service provider collects data
directly from you when their privacy policies may also apply.

Our service providers must use the personal information we share with them, or
that they collect on our behalf, only for the purposes of our engagement with
them.

With Third Parties: We may disclose personal information to third parties. The
following is a list of categories of those third parties.

 * DWM Clients: At our clients’ request, we generate lists of leads that may
   include your business contact information and other information about you in
   your professional capacity. Our clients use that information to provide you
   with relevant marketing communications.
 * Social Media Platforms: Where you choose to interact with us through social
   media, your interaction with these programs typically allows the social media
   company to collect some information about you. Please visit the social media
   companies’ respective privacy policies to better understand their data
   collection practices and controls they make available to you.
 * Advertising, Marketing, and Analytics Partners: We partner with companies
   that assist us with marketing our Sites and our clients’ products and
   services, including by “remarketing” to you on other websites, apps, or
   social media platforms. These companies may collect information from you
   automatically via cookies or other tracking technologies when you use our
   Sites.  


YOUR RIGHTS



In this Policy, “personal information” means information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular individual.

The law gives you rights related to your personal information. To make a request
to exercise your rights, click here. 

Your Rights: Individuals from different countries or jurisdictions may have
different rights. We reserve the ability to limit our response to your request
to exercise your rights based on the law that is applicable to you, but our goal
is to treat everyone equally. 

 * Transparency: At the time we collect personal information, you have the right
   to receive notice of the categories of personal information we collect, and
   the purposes for which those categories of personal information will be used.
   This notice should be provided at or before the time of collection.
 * Access/Right to Know: You have the right to request access to personal
   information we collected about you and information regarding the source of
   that personal information, the purposes for which we collect it, and the
   third parties and service providers with whom we share it.
 * Correction: You have the right to request that we correct the personal
   information we hold about you if it is inaccurate or incomplete.
 * Deletion: You have the right to request that we erase data we have collected
   from you. Please note that we may have a reason to deny your deletion request
   or delete data in a more limited way than you anticipated, e.g., because of a
   legal obligation to retain it.
 * Restrict Processing: You have the right to request that we limit our
   processing of the personal information we hold about you if we are processing
   such information based on legitimate interests or the performance of a task
   in the public interest as an exercise of official authority (including
   profiling); using your data for direct marketing (including profiling); or
   processing your data for purposes of scientific or historical research and
   statistics.
 * Opt-Out of Sale: You have the right to request that we stop “selling” your
   personal information as that that term is defined in the California Consumer
   Privacy Act. A “sale” of personal information is defined broadly: “selling,
   renting, releasing, disclosing, disseminating, making available,
   transferring, or otherwise communicating orally, in writing, or by electronic
   or other means, a consumer’s personal information by the business to another
   business or a third party for monetary or other valuable consideration.”
   Please see below for more information about our “sales” of personal
   information. To opt-out, please see our Do Not Sell My Personal
   Information page.

California Residents’ Privacy Rights:

 * California “Shine the Light”/Third Party Marketing: Residents of the State of
   California have the right to request information from DWM regarding other
   companies to whom DWM has disclosed certain categories of information during
   the preceding year for those other companies’ direct marketing purposes. If
   you are a California resident and would like to make such a request, please
   use the contact information provided above.
 * California Consumer Privacy Act (“CCPA”): 
   * Categories of personal information we disclose: We may disclose any of the
     categories of personal information listed above and use them for the
     above-listed purposes or for other business or operational purposes
     compatible with the context in which the personal information was
     collected. Our disclosures of personal information include disclosures to
     our “service providers,” which are companies that we engage for business
     purposes to conduct activities on our behalf. The categories of service
     providers with whom we share information and the services they provide are
     described above.
   * Categories of personal information we “sell”: We may “sell” the following
     categories of personal information listed above to third parties: Personal
     Identifiers (please note that any Personal Identifiers that are disclosed
     to our clients are limited to your business or professional contact
     information); Internet or Other Electronic Network Activity Information;
     and Geolocation Information (only IP address). To opt-out of such sales,
     please see our Do Not Sell My Personal Information page.

Individuals Located in the European Economic Area, the United Kingdom, and
Switzerland:

 * Lawful bases of processing: We process personal information on the following
   legal bases: (1) with your consent; (2) as necessary to perform our agreement
   with you to provide Sites; and (3) as necessary for our legitimate interests
   in providing the Sites where those interests do not override your fundamental
   rights and freedoms related to data privacy. 
 * Cross-border Transfer: Information we collect may be transferred to, and
   stored and processed in, the United States or any other country. We use
   appropriate data transfer mechanisms to lawfully transfer such information.
 * Complaints: Users that reside in the EEA, UK, or Switzerland have the right
   to lodge a complaint about our data collection and processing actions with
   the supervisory authority concerned. Contact details for data protection
   authorities are available here.

Special Information for Nevada Residents: 

 * Residents of the State of Nevada have the right to opt out of the sale of
   certain pieces of their information to other companies who will sell or
   license their information to others. At this time, DWM does not engage in
   such sales. If you are a Nevada resident and would like more information
   about our data sharing practices, please use the contact information provided
   above.


OPTIONS TO CONTROL YOUR PERSONAL INFORMATION



Verification Procedures: We must verify your identity for everyone’s protection,
so we may require you to provide us with verification information prior to
accessing any records containing personal information about you. We do this by:

 * Asking you to provide personal identifiers we can match against information
   we may have collected from you previously and confirm your request using the
   email or telephone account stated in the request; or
 * Having you submit your request through your account page, which will
   automatically verify your identity and will result in faster processing of
   your request.

If you are a California resident, you may authorize another individual or a
business registered with the California Secretary of State, called an authorized
agent, to make requests on your behalf. We require that you and the individual
complete notarized affidavits in order to verify the identity of the authorized
agent and confirm that you have authorized them to act on your behalf. Parents
of minor children may submit a birth of the child certificate in lieu of an
affidavit, in order to make requests on the child’s behalf.

We will use the information you provide for verification only for the purpose of
verification. We may have a reason under the law why we do not have to respond
to your request, or respond to it in a more limited way than you anticipated. If
we do, we will explain that to you in our response.

Your Account: Please visit the “Manage My Subscription” page
(http://www.ebulletins.com/manage) to update your subscription preferences.

Marketing and Other Communications: If at any time you would like to unsubscribe
from receiving future emails, you can click the unsubscribe link at the bottom
of any email communication, or email us at privacy@demandworksmedia.com and we
will promptly remove you from all correspondence.

Opt-out of “sale”: You have the right to opt out of our “sale” of personal
information to third parties. Please see our Do Not Sell My Personal
Information link to make your opt-out request and our description of your rights
above.

Cookie Management, Personalized Advertising, and Do Not Track: 

 * You can control the cookies on our website using our cookie management
   settings, here.
 * You can control cookies using your web browser’s settings. If you delete your
   cookies or if you set your browser to decline cookies, some features of the
   sites may not be available, work, or work as designed. 
 * You can use our partners’ links above to learn more about the options they
   may make available to opt-out of their tracking technologies. 
 * You can broadly opt out of participating companies’ website tracking
   technologies by visiting the websites for the Network Advertising Initiative,
   the Digital Advertising Alliance, and the European Interactive Digital
   Advertising Initiative. 
 * Similarly, you can learn about your options to opt out of mobile app tracking
   by some advertising networks through your device settings and by resetting
   the advertiser ID on your mobile device.

When you make an opt-out choice, it does not necessarily mean that you will stop
receiving ads altogether, but you will no longer receive personalized ads. 

If you delete your cookies, you may also delete your opt-out preferences.

Your browser or device may include “Do Not Track” functionality. At this time,
DWM does not respond to browser “Do Not Track” signals.


OTHER INFORMATION ABOUT OUR DATA PROCESSING



Retention: We will retain information for as long as necessary for the uses set
out in this Policy, or while there is a legitimate reason for doing so. If you
ask us to delete your information before that time, we may not be able to do so
due to legal, regulatory or contractual constraints. For example, we would need
to retain your name and contact details for suppression purposes if you do not
want to receive direct marketing from us.

Security: We use a combination of physical, technical, and administrative
safeguards to protect the information we collect through the Sites. While we use
these precautions to safeguard your information, we cannot guarantee the
security of the networks, systems, servers, devices, and databases we operate or
that are operated on our behalf.

Sharing of Aggregated Data: We may analyze aggregated, de-identified data and
share these analyses at our discretion, including with marketing agencies, media
agencies and analytics providers. These other companies will not be able to
relate this data to identifiable individuals.

Combination of Information: We may combine information from the Sites together
and with other information we obtain from our business records. Additionally,
information collected about you from a particular browser or device may be
linked to information collected from another computer or device that we believe
relates to you.

Change of Ownership or Corporate Organization: We may transfer to another entity
or its affiliates or service providers some or all information about you in
connection with, or during negotiations of, any merger, acquisition, sale of
assets or any line of business, change in ownership control, or financing
transaction. We cannot promise that an acquiring party or the merged entity will
have the same privacy practices or treat your information the same as described
in this Policy.

Cross-border Transfer of Data: If you use our Sites outside of the United
States, you understand that we may collect, process, and store your information
in the United States and other countries. The laws in the U.S. regarding
information may be different from the laws of your state or country. Any such
transfers will comply with safeguards as required by relevant law. 

CONTACT INFORMATION

Questions regarding this Policy should be submitted to DWM:

DemandWorks Media
444 N. Michigan Avenue, Suite 1200
Chicago, IL 60611
(312) 204-7275

Email: privacy@demandworksmedia.com

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