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We value your privacy
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Privacy Statement


PRIVACY AND DATA SECURITY STATEMENT



Thank you for visiting Slashdot Media’s online and mobile resources, and for
viewing this privacy and data security statement. Our full privacy statement,
contained in the pages that follow, serves to give notice about the types of
personal data we collect, how we use it, who we share it with and why, and what
we do to try to protect it. We encourage you to read our full statement
carefully.


 * YOUR PRIVACY CHOICES AND RIGHTS

You do not have to provide personal data to enjoy most of the features of our
online and mobile resources. Moreover, you can opt out of certain activities
like newsletters and announcements. You can learn more about that here.

This privacy statement was amended as of January 1, 2023 and is effective as of
that date. The English language version of this privacy statement is the
controlling version regardless of any translation you may attempt.


SOME IMPORTANT VOCABULARY

Although not itself a contract, this privacy statement is an important document
that explains how we address some of our legal obligations, and your related
legal rights, involving personal data. Clarity is, therefore, important. We will
use this section to let you know about some words that have special meanings
whenever you see them in this statement.

Let’s start with the word "statement" itself: when we reference "this
statement", "this privacy statement" and "our statement", we mean the Privacy
and Data Security Statement you are reading now. Wherever we say "Company, "we",
"us", our, or "SDM", we mean Slashdot Media LLC and the various websites that we
own and operate linked to this statement. We use the words "you" and your to
mean you, the reader, and other visitors to our online and mobile resources who
are, in all cases, over the age of 18. This age requirement is discussed in more
detail later in this statement here.

When we talk about our "online and mobile resources", we mean all websites,
portals, or other features SDM operates, as well as the mobile apps we’ve
created and distributed to let you interact with the content we provide. Those
online and mobile resources include, and this statement covers,
SlashdotMedia.com, SourceForge.net, Slashdot.org, wirefly.com, myrateplan.com,
voipreview.org, linuxjournal.com and tmonews.com. SDM also offers certain
business-to-business marketing and advertising services. When we refer to "lead
ads and content" we mean the special types of advertisements and other content,
such as whitepapers and email contents, containing forms or other means for
users to provide information showing their interest in the applicable product or
service. We do our best to make sure each of our online and mobile resources, as
well as lead ads and content, link to this statement. In referring to an
"affinity action" it means when you "follow" us, "like" us or take a similar or
analogous action on our external social media presence.

Finally, and perhaps most importantly, when we refer to "personal data", we mean
any information, data or data element, whether in electronic or other form,
that, alone or in combination with other elements, can be used to distinguish,
trace, or discover your identity. Certain data privacy laws include specific
elements or defined terms for what they consider to be the personal data (or
personal information) they govern. Where such data privacy laws apply, then the
term "personal data" includes the specific elements and defined terms required
by such laws.


WHO DO WE COLLECT PERSONAL DATA FROM?

We collect personal data from the following groups of data subjects:

 * visitors to, users of, and those that interact with our online and mobile
   resources ads and content ("Visitors and Users")
 * customers of our advertising marketing and lead generation services
   ("Customers")
 * members of our workforce and those who apply for posted jobs ("Our Workforce
   and Job Applicants")
 * our third-party vendors and business partners ("Vendors and Business
   Partners")

The categories of data we collect from each of these groups, and the ways in
which we use it, differs.

OUR VISITORS AND USERS

This privacy statement applies only to Visitors and Users of our online and
mobile resources and those that interact with our lead generation ads and
content including content we may send as part of email campaigns. Thus, the
words "you" and "your" throughout this privacy statement mean only those
categories of data subjects. In the case of Comprehensive Privacy Laws, "you"
and "your" are further defined below in relation to those laws.

OUR CUSTOMERS

Our customers enter into contracts with us. That contract is separate from this
statement and has its own terms and conditions for notice of collection of
personal data and governing our overall confidentiality, data privacy and data
security obligations. As a result, those terms, and not this statement, apply to
the personal data of customers.

OUR WORKFORCE AND JOB APPLICANTS

We collect and retain the types of professional or employment related personal
data you would expect an employer to have about its workforce and job
applicants. We provide legally required notices of collection and describe our
use and sharing of the personal data of our workforce and applicants in greater
detail in confidential internal human resource manuals and documents accessible
to members of our workforce.

OUR VENDORS AND BUSINESS PARTNERS

Like all corporate enterprises, we buy goods and services, lease equipment and
office space and attend industry events. In doing so, we interact with existing
and potential vendors and business partners from whom we necessarily collect
certain personal data. We describe our use of vendor and business partner
personal data in greater detail in our confidential contracts with those
parties.


WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

We collect personal data in three ways: (i) personal data you voluntarily
provide to us; (ii) personal data we collect through automated/technical means;
and (iii) personal data that you have previously made available publicly or to
other sources. We describe that type of voluntary submission and automatic
collection in the tables below. By using our online and mobile resources, you
are signifying to us that you agree with this section of our privacy statement
and that we may use and disclose your data as described.

VOLUNTARILY SUBMITTED DATA

If you choose to participate in or make use of certain activities and features
available via our online and mobile resources, you will need to provide us with
data about yourself. The types of personal data you will be submitting to us in
those situations is almost always limited to basic identifiers such as your
name, email address, mailing address and phone number. Below are some of the
ways you voluntarily give us your personal data:


DATA WE COLLECT VOLUNTARILY PROVIDED BY YOU WHEN YOU REGISTER ON OUR SITE, FILL
OUT A FORM, WRITE A REVIEW, WRITE A COMMENT, INTERACT WITH WEBSITE TOOLS, UPLOAD
IMAGES OR CONTENT, E-MAIL US OR SUBSCRIBE TO ONE OF OUR EMAIL LISTS. THIS DATA
IS DIRECTLY PROVIDED BY YOU.

Categories of data we collect voluntarily from you include:

 * If you register as a user, we collect personal data such as your full name,
   business or personal email address, job title, the name of your company,
   industry sector, and your telephone number;
 * Other information and data you may provide when writing a review, submitting
   a forum or blog post, submitting a comment, submitting a support or bug
   ticket, editing a wiki, uploading files or images, open-source code, or
   inbound emailing to an open-source project list.
 * Other data you provide when you communicate with us including your full name,
   contact details and business email address, phone number and details of any
   such communications.

We use this data for certain activities, including:

 * Verifying the validity of your review(s) and ensuring that false, misleading
   or malicious reviews are not posted:
 * Sending you email including, but not limited to service announcements,
   account related messages, project related updates, subscribed newsletters;
 * Sending marketing information and offers to business contacts regarding
   Slashdot Media services;
 * Inviting you to provide reviews about other products and services, and to
   consider other services provided by Slashdot Media;
 * Providing our services, managing our website, responding to your questions,
   investigating any complaints, and providing customer service;
 * Customize your digital markets experience;
 * Resolving disputes;
 * For internal analytical and research purposes to help us to measure interest
   in and improve our services;
 * Preventing prohibited or illegal activities;
 * Enforcing our policies.

We use this data because:

 * We have a legitimate business interest to:
 * * Manage and promote our business and brand;
   * Provide and improve our services;
   * Operate our business;
   * Improve the performance and user experience of our websites;
   * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Resolve any concerns or disputes you may have

AUTOMATICALLY COLLECTED DATA

When you visit our sites or use our online and mobile resources, basic data
about your internet/electronic activity is automatically collected through your
browser via tracking technologies, such as “cookies.” As just about everyone
knows by now, cookies are small text files downloaded onto your computer or
mobile device. Cookies allow us to collect your IP address and recognize your
computer or mobile device and store some data about your preferences for using
our online and mobile resources or past actions, such as described in the table
below:


DATA WE COLLECT ABOUT YOUR USE OF OUR WEBSITE AND APPS (AUTOMATICALLY
COLLECTED).

Categories of data we collect automatically about you include:

 * Data recorded in our logs, including URL, IP address, browser & OS data,
   timestamp, referring site, geolocation, and other standard browser data;
 * Behavioral data (such as data on the behavior or presumed interests of
   individuals which are linked to those individuals and may be used to create a
   user profile) pages viewed, images viewed, documents downloaded and links to
   other sites followed;
 * Data captured by our cookies (see our Cookie Policy).

We use this data for certain activities, including:

 * To personalize your experience on our website;
 * Operating our website, developing, and improving our products and services;
 * Analytical, statistical and trend analysis to improve the user experience and
   performance of our website;
 * Facilitate your access to and use of our website;
 * Resolving disputes and troubleshooting problems.

We use this data because:

 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
 * * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Improve the performance and user experience of our websites;
   * Develop our product and service offerings for service users.
   * You have given us your consent (where required under applicable law) to use
     your data for marketing. Where we rely on your consent, you have the right
     to withdraw this consent by contacting us using the information above or
     unsubscribing via the opt-out functionality provided in our marketing
     communications to you
   * Resolve any concerns or disputes you may have.



DATA PROVIDED BY YOU DIRECTLY THAT WE COLLECT WHEN YOU:

 * Create or claim a free or paid listing
 * Connect with Slashdot Media sales representatives
 * Register for an account with us
 * Correspond with us (either by phone or email)

Categories of data we collect automatically about you include:

 * Personal data such as your full name and contact details such as the name of
   your company, the state/county in which you are based, business email
   address, your telephone number and job title;
 * Your company website URL;
 * What you are interested in hearing about (e.g., lead generation or website
   review);
 * What advertising channels you use such as pay per click, pay per view, fixed
   or other advertising channels;
 * Data about the software you offer, e.g., the product name, type of software
   and product description;
 * Data we require so we may invoice you, including your payment details and
   billing data; and Other data you provide when you communicate with us,
   including your full name, contact details and business email address, phone
   number and details of our communications.

We use this data for certain activities, including:

 * Fulfilling your requests, for example, to publish your listing and other
   submitted content, to provide you with details of leads (including their
   name, data about their business, software requirements and follow up next
   steps (e.g., request demo), and to invoice you appropriately;
 * Managing your profile and listings;
 * Sending you service emails (e.g., service announcements and messages relating
   to your account);
 * Providing consultation services;
 * Notifying you about special offers available from us, our affiliates or
   partners, which may be of interest to you;
 * Sending marketing to business contacts regarding our services and products
   which may be of interest and to promote our business and brand;
 * Administering our services and website, investigating any complaints and
   providing customer service;
 * Responding to your questions and requests and otherwise customize your
   digital markets experience;
 * Resolving disputes;
 * For internal analysis and research to help us to measure interest in and
   improve our services;
 * Preventing prohibited or illegal activities;
 * Enforcing our policies.

We use this data because:

 * We have a legitimate business interest to:
 * * Manage and promote our business and brand;
   * Provide and improve our services;
   * Operate our business;
   * Obtain payment for our services;
   * Improve the performance and user experience of our websites;
   * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Resolve any concerns or disputes you may have.
 * We have collected your consent (where required under applicable law) to use
   your data for marketing. Where we rely upon your consent, you have the right
   to withdraw this consent by contacting the Data Protection Officer on the
   contact details above or unsubscribing via the opt-out functionality provided
   in our marketing communications to you.

If you prefer, we not receive the above-described personal data, please do not
submit it. This means you should not participate in the applicable activities on
or use the applicable features available from our online and mobile resources.
Such participation and use are strictly your choice. By not participating, you
may limit your ability to take full advantage of the online and mobile
resources, but most of the content in our online and mobile resources will still
be available to you.

Additional data about cookies and tracking technologies is available here.

If you access our online and mobile resources from a phone or other mobile
device, the mobile services provider may transmit to us certain data such as
uniquely identifiable mobile device data. That, in turn, allows us to collect
mobile phone numbers and associate them with the mobile device identification
data. Some mobile phone service providers also operate systems that pinpoint the
physical location of devices, and we may receive this geolocation data as well.

When you use our online and mobile resources, we may allow third party service
providers to place their own cookies or similar technologies to engage in the
same types of collection we describe above.

Finally, there is a category of personal data we may collect that does not fit
neatly into the “voluntarily submitted” or “automatically collected” categories.
If you use both our app and a third party mail service (such as Google’s Gmail,
Yahoo! Mail and the like) on your mobile device, you may have activated a
setting that allows us to use certain technologies such as application
programming interfaces, to automatically access (sometimes referred to as
“parse”) your mail as it relates to your use of our app. If you did activate the
setting allowing us to do so, our use of any data we receive from those
technologies will adhere to the requirements of the publisher of the applicable
technology. This includes, if we use Google APIs, adhering to the Google API
Services User Data Policy and its Limited Use requirements.

DATA COLLECTED FROM OTHER SOURCES

As part of our services, we will sometimes initially identify prospective
customers via public websites or applications operated by third parties such as
Seamless.ai. The type of data we collect is the same as that described above,
such as name, email address, mailing address and phone number, as well as
potentially workplace and job title. We purchase data sets from third parties
and use them to check the accuracy of the data we collected from such public
sources. In some cases, we may use the data we purchased from a third party even
if we did not previously collect it from a public source. We exercise reasonable
care and due diligence in purchasing data from third parties and only do so when
we are able to obtain assurances that they obtained personal data in a lawful
manner.

USER BEWARE: EXTERNAL SITES, APPS, LINKS AND SOCIAL MEDIA

We maintain a presence on one or more external social media platforms such as
Twitter, Facebook, Instagram, and LinkedIn. We may further allow the community
features of our online and mobile resources to connect with, or be viewable
from, that external social media presence. Similarly, our online and mobile
resources may contain links to other websites or apps controlled by third
parties.

We are not responsible for the content on, or the privacy practices of, social
media platforms, or any third-party sites or apps to which we link. Those apps,
sites and platforms are not controlled by us and therefore have their own
privacy policies and terms of use. To be clear: neither this statement nor the
terms of use appearing on or in any of our online and mobile resources apply to
our social media presence or any third-party sites or apps to which we may link.
That means even if you take an affinity action on our specific social media
profile, and identifiers about you are automatically collected and given to us
as a result, that collection and transfer is governed by the privacy policies
and other terms of the applicable social media platform and are not our
responsibility. If you have questions about how those apps, sites and platforms
collect and use personal data, you should carefully read their privacy policies
and contact them using the data they provide.


HOW DO WE USE THE PERSONAL DATA WE COLLECT?

We use the personal data we collect only in the manner and through the means
allowed by applicable law. That means we determine whether we have a lawful
basis/legitimate business purpose to use your personal data before doing so. As
stated in applicable law, such lawful bases/legitimate business purposes may
include receiving express consent, operating our business, performing a
contract, and complying with a legal obligation. More specifically, we use the
personal data as follows:

We use the automatically collected personal data described here to compile
generic reports about popular pages/features of our online and mobile resources,
and to see how users are accessing our online and mobile resources and, in some
cases, (such as affinity actions) send materials to you. We use the personal
data you voluntarily submitted, as described here, to respond back directly to
you and/or send you the data you requested or about which you inquired. We also
may use any such personal data you provide to customize our programs and
newsletters to make them more relevant to you. We use the personal data that we
collect from other sources to contact prospective customers and provide them
with details regarding our services. In limited cases we do sell personal data
which you voluntarily provide when using our online and mobile resources. We
describe those cases in this section.

We use and retain your personal data in accordance with applicable law and only
as long as necessary to carry out the purposes described above in accordance
with our internal data retention procedures.


HOW LONG DO WE KEEP YOUR PERSONAL DATA

We retain your personal data for a period of time consistent with the purpose of
collection and processing, required to fulfill our legal obligations and for
enforcing our agreements. The retention period for personal data is determined
by us based on the amount, nature, and sensitivity of the personal data being
processed, the potential risk of harm from unauthorized use or disclosure of the
personal data, whether we can achieve the purposes of the processing through
other means, and any applicable legal requirements. For example, we will retain
certain identifiers for as long as it is necessary to continue maintaining your
account and providing you our products and services, to comply with our tax,
accounting, and recordkeeping obligations, to administer certain warranties, and
for research, development, and safety purposes, as well as an additional period
as necessary to protect, defend, or establish our rights, defend against
potential claims, and to comply with our legal obligations. Typically, after
expiry of the applicable retention periods, your personal data will be deleted,
unless such deletion is rendered impractical or unreasonably burdensome due
technical or other reasons, including where it becomes technically impossible,
data retained as part of automatic archiving and back-up procedures, In such
cases where any information is retained, We will implement appropriate measures
designed to prevent misuse of such data. In certain circumstances, we may
anonymize your personal data so that it can no longer be associated with you, in
which case we may use such data without further notice to you.


WHEN/WITH WHOM DO WE SHARE PERSONAL DATA?

We may share your personal data as described below. This sharing applies to the
personal data of all four groups of data subjects.

AFFILIATES

We may share personal data with other corporate affiliates who will use such
data in the same way as we can under this statement.

LEGAL REQUIREMENTS

We may disclose personal data to government authorities, and to other third
parties when compelled to do so by such government authorities, or at our
discretion or otherwise as required or permitted by law, including responding to
court orders and subpoenas.

TO PREVENT HARM

We also may disclose such data when we have reason to believe that someone is
causing injury to or interference with our rights or property or harming or
potentially harming other persons or property.

BUSINESS SALE/PURCHASE

If we, or any of our affiliates, sell or transfer all or substantially all of
our assets, equity interests or securities, or are acquired by one or more third
parties as a result of an acquisition, merger, sale, reorganization,
divestiture, consolidation, or liquidation, personal data may be one of the
transferred assets.

VENDORS AND BUSINESS PARTNERS

We also share personal data with those of our vendors and business partners who
need it to perform under the contracts we have with them. As part of our
Security Program, we have adopted standards for those vendors and business
partners who receive personal data from us. We attempt to bind such vendors and
business partners to those standards via written contracts. Such standards
include expectations that when we share personal data with our vendors and
business partners, they will comply with all applicable privacy and data
security laws and regulations and our Security Program and will contractually
require and cause their subcontractors and agents to do the same

For any personal data, our vendors and business partners process or store at
their own locations, we further expect them to use technology infrastructure
meeting, at least at the facilities level, minimum recognized standards for
security controls. Such recognized standards include those published by the
International Standards Organization, the National Institute of Standards and
Technology or any reasonably equivalent standards.

Please note, however, that we cannot guarantee that all our vendors and business
partners will agree to the above-described contractual requirements; nor can we
ensure that, even when they do agree, they will always fully comply.


HOW LONG DO WE KEEP YOUR PERSONAL DATA

OUR DATA SECURITY PROGRAM

We have adopted, implemented, and maintain an enterprise-wide corporate data
security and privacy program that includes technical, organizational,
administrative, and other security measures designed to protect, as required by
applicable law, against reasonably anticipated or actual threats to the security
of your personal data (the "Security Program"). Our Security Program was created
with reference to widely recognized industry standards such as those published
by the International Standards Organization and the National Institute of
Standards and Technology. It includes, among many other things, procedures for
assessing the need for and employing encryption and multi-factor authentication
as appropriate or using equivalent compensating controls. We therefore have
every reason to believe our Security Program is reasonable and appropriate for
our business and the nature of foreseeable risks to the personal data we
collect. We further periodically review and update our Security Program,
including as required by applicable law.

OUR INCIDENT RESPONSE AND MANAGEMENT PLAN

Despite the significant investment we’ve made in, and our commitment to, the
Security Program including enforcement of our third party oversight procedures,
we cannot guarantee that your personal data, whether during transmission or
while stored on our systems, otherwise in our care, or the care of our vendors
and business partners, will be free from either failed or successful attempts at
unauthorized access or that loss or accidental destruction will never occur.
Except for our duty under applicable law to maintain the Security Program, we
necessarily disclaim, to the maximum extent the law allows any other liability
for any such theft or loss of, unauthorized access or damage to, or interception
of any data or communications including personal data.

All that said, as part of our Security Program, we have specific incident
response and management procedures that are activated whenever we become aware
that your personal data was likely to have been compromised. Those procedures
include mechanisms to provide, when circumstances and/or our legal obligations
warrant, notice to all affected data subjects within the timeframes required by
law, as well as to give them such other mitigation and protection services (such
as the credit monitoring and identity theft insurance) as may be required by
applicable law. We further require, as part of our vendor and business partner
oversight procedures, that such parties notify us at least within the timeframes
required by law if they have any reason to believe that an incident adversely
affecting personal data we provided to them has occurred.


YOUR GENERAL RIGHTS AND OPTIONS

If we are using your personal data to send you marketing materials, such as
newsletters or product alerts via text or email, you may opt out by following
the opt-out instructions linked or otherwise provided in the applicable email or
other communication (e.g., by responding to the text with “STOP”). In addition,
certain of our online and mobile resources will provide a centralized opt-out
link allowing you to opt out of any programs in which you may have enrolled
using that online and mobile resource. When we receive your request, we will
take reasonable steps to remove your name from our distribution lists, but it
may take time to do so. You may still receive materials for a period of time
after you opt out. Opting out of or changing affinity actions or other
submissions or requests made on our external social media presence, require that
you do so directly on that applicable platform as we do not control their
procedures.

Some browsers have a do not track (“DNT”) feature that lets you tell websites
that you do not want to have your online activities tracked. We do not support
DNT. We do support Global Privacy Control ("GPC") in jurisdictions that require
it such as California. The GPC signal communicates a Do Not Sell request from a
global privacy control, as per CCPA-REGULATIONS §999.315 if enabled for that
browser or device, or, the data subject if they can be identified.

You also have additional rights under certain laws to withdraw consent and to
instruct us not to sell your personal data. We describe those rights and the
procedure for exercising them here.


CHILDREN’S PRIVACY

Federal law imposes special restrictions and obligations on commercial website
operators who direct their operations toward and collect and use /data from
children under the age of 13. We take those age-related requirements very
seriously, and, consistent with them, do not intend for our online and mobile
resources to be used by children under the age of 18, and certainly not by those
under the age of 13. Moreover, we do not knowingly collect personal data from
minors under the age of 18. If we become aware that anyone under the age of 18
has submitted personal data to us via our online and mobile resources, we will
delete that data and not use it for any purpose whatsoever. We encourage parents
and legal guardians to talk with their children about the potential risks of
providing personal data over the Internet.


COMPREHENSIVE PRIVACY LAWS

Privacy and data protection laws vary around the world and among the individual
United States. Our obligations arising under the majority of the world’s privacy
laws, including U.S. federal and most state laws, are satisfied by individual
risk assessments that we conduct to ensure we act reasonably and responsibly
when processing your personal data. In some jurisdictions, however, privacy laws
grant you, the data subject, certain specific rights regarding your personal
data. We refer to these types of privacy laws as "Comprehensive Privacy Laws."
Examples of Comprehensive Privacy Laws include the European Union ("EU GDPR"),
and United Kingdom’s ("UK GDPR") variants of the General Data Protection
Regulation (collectively, the "GDPR"), and the consumer privacy statutes of
several U.S. states, such as California, Colorado, Utah, and Virginia. In other
jurisdictions, such as Nevada, privacy laws have some features of Comprehensive
Privacy Laws such as the right to opt-out of the sale of your personal data.

The nature and locations of our business activities make us subject to some,
though not necessarily all, Comprehensive Privacy Laws. We are for instance,
subject to the California Consumer Privacy Act, or "CCPA" and the GDPR. As such,
when we collect personal data from data subjects protected by the CCPA or GDPR,
we become subject to, and those data subjects have rights under, those
Comprehensive Privacy Laws. This section of our statement is used to explain
your rights under those laws. For purposes of this section, the words "you" and
"your" mean only California consumers (as defined by CCPA) and data subjects
whose personal data was collected while they were in a GDPR jurisdiction.

Questions about how the Comprehensive Privacy Laws of other jurisdictions might
apply to us can be directed to us through the contact data found here.

YOUR RIGHTS AND OUR OBLIGATIONS UNDER THE CCPA

CATEGORIES OF DATA COLLECTED

We collected the following categories of personal data within the last 12
months:

 * identifiers such as name, address, IP address, and other similar identifiers
 * personal data under the Customer Records provision of the California Civil
   Code such as a name, address, telephone number, credit card number
 * commercial data such as products or services purchased
 * biometric data such as fingerprints or facial or retina scans
 * internet/electronic activity such as browsing history and search history
 * geolocation data including geographic coordinates/physical location
 * audio, video, electronic or other similar data
 * professional or employment related data such as job history and performance
   evaluations
 * Education data
 * inferences drawn from the foregoing to create a profile about a consumer
   reflecting the consumer’s preferences, characteristics, psychological traits,
   predispositions, behavior, attitudes, intelligence abilities and aptitudes.

WHAT PERSONAL DATA DID WE DISCLOSE FOR A BUSINESS PURPOSE?

We may have disclosed the categories of personal data listed above for one or
more business purposes permitted by the CCPA during the last 12 months.

WHAT PERSONAL DATA DID WE SELL?

As a data-driven business-to-business demand generation marketing and technology
company, we provide services to help our customers understand and expand their
audiences such as email marketing, lead generation and advertising. As part of
those services, we collect certain personal data that is then sold as part of
our broader service offerings. In almost all cases, only a name, email address,
work title and location and a phone number will be sold. When we collect
personal data intended for sale, we provide you with a mechanism to
affirmatively consent at the time of collection. You can later withdraw that
consent, and otherwise instruct us not to sell, or further sell your data at any
time by visiting our opt-out/do not sell portal found here.

WHAT SOURCES DID WE OBTAIN PERSONAL DATA FROM AND FOR WHAT OTHER REASONS DID WE
COLLECT IT?

Please re-review this part of this privacy statement to understand the scope of
purposes and the sources from which we collect it. Similarly, we urge you to
re-read this part of this statement where we describe the categories of third
parties with which we may share your personal data and why.

RIGHTS TO KNOW AND ACCESS

California residents have the following rights under the CCPA. If you exercise
these rights, we will not discriminate against you by treating you differently
from other California residents who use our sites and mobile resources or
purchase our services but did not exercise their rights.

 * Know – You have the right to request that we disclose to you, specifically
   beyond the general statement immediately above, the categories and specific
   elements of personal data collected including the source of the data, our use
   of it and, if the data was disclosed or sold to third parties, the categories
   so disclosed or sold as well as the categories of third party who received or
   purchased it.
 * Access – You have the right to receive a copy of the categories and specific
   elements of personal data we collected about you in the preceding 12 months.
 * Correct – You have the right to request the correction of inaccurate
   information collected.
 * Delete – You the right to request the deletion of personal data We collected
   about you held by Us, Our service providers, contractors or any other third
   party We have disclosed your personal data to under certain circumstances.
 * Opt Out – You have the right to opt out of any sale or sharing of personal
   data (as defined in the CCPA) if such sale or sharing occurs.
 * Transfer – You have the right to request the transfer of specific pieces of
   information We have collected about you to another entity.
 * Sensitive Information – The right to limit the disclosure of sensitive
   personal data in specific instances as set forth in the CCPA.

We support Global Privacy Control “(GPC”). The GPC signal communicates an
Opt-Out/Do Not Sell request from a global privacy control, as per
CCPA-REGULATIONS §999.315 if enabled for that browser or device, or, the data
subject if they can be identified. If you opt-out using the GPC functionality
available in some browsers while you are logged in to one of our sites or
portals, we will use that signal to opt you out of all online and offline
marketing and sharing. If your browser functionality supports GPC but you are
not logged into one of our sites or portals we will use that signal to opt you
out of online tracking only. If your browser does not support GPC you can click
on the Do Not Sell link at the bottom of our site to activate our cookie manager
where you can select your opt out choices for browser activity. If you email or
write to us with an opt out request, we will use that request to opt you out of
all offline based marketing and sharing and any online based marketing and
sharing when you are logged into your account in one of our sites or portals.

In addition to the rights described above, you, or an authorized agent acting on
your behalf, can exercise the Right to Know up to two different times every 12
months. To exercise these rights, you or your agent must contact us via any of
the four means listed here. We may ask you to fill out a request form. The CCPA
only allows us to act on your request if we can verify your identity and/or your
agent’s authority to make the request, so you will also need to follow our
instructions for identity verification. If you make a verifiable request per the
above, we will confirm our receipt and respond in the time frames prescribed by
the CCPA.

YOUR RIGHTS AND OUR OBLIGATIONS UNDER NEVADA PRIVACY LAW

If you are Nevada resident, Nevada law (SB 220), entitles you to opt out of the
sale of certain kinds of personal data. A sale under Nevada law is the transfer
of this personal data to third parties for monetary consideration. If you are a
Nevada resident and wish to opt-out, you may do so by contacting us at any of
the 4 methods here or click on the Opt-Out link at the bottom of our site

YOUR RIGHTS AND OUR OBLIGATIONS UNDER THE GDPR

When we collect personal data from individuals located in the European Economic
Area and the United Kingdom (the "GDPR Jurisdictions"), those individuals have
rights under the GDPR. This section of our statement is used to fulfill our GDPR
obligations and explain your GDPR rights. For purposes of this section, the
words "you" and "your" mean only such individuals located in the GDPR
Jurisdictions.

OUR COLLECTION, USE, AND SHARING PRACTICES

Please review this section to understand the scope of purposes and the sources
from which we collect personal data. Similarly, you can find data about the
categories of third parties with which we may share your personal data and why
we share it in this section. We do not use your personal data for automated
decision-making. We do, however, collect certain personal data for the purpose
of selling it as described here. We also purchase certain personal data from
third parties. If we are reasonably aware that such third parties have not
provided you with appropriate notice of collection as required under GDPR
Article 13, we will provide you the required alternate notice under Article 14
when we first contact you using such data. We typically provide that Article 14
notice in the body of the communication used to contact you.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Our legal basis for collecting and using your personal data will depend on the
personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data where the processing is in our
legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms, such as to contact you about products and
services you may be interested in. In certain circumstances where our legal
basis of processing is for performance of a contract with you, please be aware
that, in those circumstances, where you do not provide personal data, which is
required by us, we will not be able to provide the products and services under
our contract with you or may not be able to comply with a legal obligation on
us. In some cases, we may also have a legal obligation to collect personal data
from you or may otherwise need the personal data to protect your vital interests
or those of another person. If we happen to obtain your consent to process your
personal data, you may withdraw your consent at any time via any of the means
listed here.

EXERCISING YOUR RIGHTS

You may exercise the rights available to you under the GDPR, including the right
to object to the processing of your personal data, as follows:

 * Access – the right to obtain a confirmation that your personal data is being
   processed, access to your personal data (if we are in fact processing it),
   other data about the processing of your personal data (most of which is set
   forth in this statement) and a copy of the personal data we are processing.
 * Rectification – the right to have your personal data corrected if it is
   inaccurate, and depending on the purposes of processing, you may also have
   incomplete personal data completed.
 * Erasure – also known as the "right to be forgotten", the right to request
   your personal data be deleted under certain circumstances such as if it is no
   longer needed for the original purpose it was collected for or if you
   withdrew your consent. The right of erasure does not apply under limited
   circumstances including if the processing is necessary for exercising the
   right of freedom of expression and data or our compliance with a legal
   obligation.
 * Restrict processing – the right to restrict processing of your personal data
   under certain circumstances such as if you contest the accuracy of the
   personal data (and only for so long as it takes to verify that accuracy), the
   processing is unlawful and you have requested restricting the processing
   rather than erasure, or if we no longer need the personal data but you need
   it to establish, exercise or defend a legal claim.
 * Portability – the right to receive the personal data you provided to us (and
   not any other data) under limited circumstances such as if the basis for
   processing the personal data was consent or necessary for the performance of
   a contract with you, or the processing is carried out by automated means.
 * Automated Processing – the right to not be subject to a decision based solely
   on automated processing, including profiling.
 * Object to processing – the right to object to the processing of your personal
   data under the following circumstances:
   * Legitimate Interests – if the basis for which the processing occurs is in
     our legitimate interests or in the performance of a task carried out in the
     public interest. If you object, we will stop processing your personal data
     unless we can demonstrate compelling legitimate grounds for the processing
     which override your interests, rights and freedoms or we require the
     personal data to establish, exercise or defend a legal claim.
   * Direct Marketing – if the processing is for direct marketing purposes.

You can exercise these rights by contacting us using the contact data listed
here, however, we may need to request additional data from you to verify your
identity before granting your request. We will respond to all requests we
receive from individuals wishing to exercise such rights in accordance with the
GDPR. We have the ability to charge a reasonable fee for administrative costs of
providing the personal data to you in situations where the request is unfounded
or excessive (due to its repeated nature), or in the alternative, we may refuse
to act on the request in those situations

LODGING A COMPLAINT

You have the right to complain to your data protection authority about our
collection and use of your personal data. Please contact your local data
protection authority for more data. Contact data for data protection authorities
can be found here and here.

RETAINING YOUR PERSONAL DATA

We will store and retain your personal data in accordance with applicable law
and as long as necessary to carry out the purposes described in this Section in
accordance with our internal data retention procedures. The criteria used to
determine the retention periods include:

 * how long the personal data is needed in connection with the applicable
   purposes for which we use it;
 * the type of personal data collected
 * whether we are subject to a legal, contractual, or similar obligation to
   retain the personal data (e.g., mandatory data retention laws, government
   orders to preserve personal data relevant to an investigation, or personal
   data that must be retained for the purposes of litigation or disputes).

CROSS-BORDER DATA TRANSFER

By submitting personal data to us, we will, receive it in the United States
where our technical infrastructure resides. We undertake such collection solely
for the purposes described previously in this statement but note that such
direct collection does not constitute a “transfer” under the GDPR. In certain
instances, we collect personal data from data subjects located within the GDPR
Jurisdictions, and do then transfer it to the U.S., to international
organizations, and/or to third countries for the same purposes discussed above.
When doing so, may use the mechanisms prescribed for lawful transfers in GDPR
Articles 44 through 49, including, where appropriate, then-current standard
contractual clauses or similar mechanism appropriate to the particular GDPR
Jurisdiction involved. you can request further details in relation to
international transfers, including a copy of the standard contractual clauses,
by contacting us here.


CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to change or update this statement from time to time.
Please check our online and mobile resources periodically for such changes since
all data collected is subject to the statement in place at the time of
collection. Typically, we will indicate the effective/amendment date at the
beginning of this statement. If we feel it is appropriate, or if the law
requires, we will also provide a summary of changes we have made near the end of
the new statement.


HOW TO CONTACT OUR PRIVACY OFFICE

If you have any questions about our privacy and data security policies,
procedures, and practices, including anything we say in this privacy statement,
we encourage you to contact our Privacy Office.

Slashdot Media, LLC

 * Address: PO Box 12190 San Diego, CA 92122
 * Attn: Privacy Compliance
 * Phone: 1-800-552-9000
 * Slashdot Media Privacy Portal:
    * Info Request and Data Deletion
    * Do Not Sell My Personal Information

 * Email: privacy@slashdotmedia.com


INDEX

❖ Privacy And Data Security Statement
❖ Some Important Vocabulary
❖ Who Do We Collect Personal Data From?
 * ♦ Our Visitors and Users
 * ♦ Our Customers
 * ♦ Our Workforce and Job Applicants
 * ♦ Our Vendors and Business Partners

❖ What Personal Data Do We Collect About You?
 * ♦ Voluntarily Submitted Data
 * ♦ Automatically Collected Data
 * ♦ Data Collected from Other Sources
 * ♦ User Beware: External Sites, Apps, Links and Social Media

❖ How Do We Use The Personal Data We Collect?
❖ How Long Do We Keep Your Personal Data
❖ When/With Whom Do We Share Personal Data?
 * ♦ Affiliates
 * ♦ Legal Requirements
 * ♦ To Prevent Harm
 * ♦ Business Sale/Purchase
 * ♦ Vendors and Business Partners

❖ How Long Do We Keep Your Personal Data
 * ♦ Our Data Security Program
 * ♦ Our Incident Response and Management Plan

❖Your General Rights And Options
❖ Children’s Privacy
❖ Comprehensive Privacy Laws
 * ♦ Your Rights and Our Obligations under the CCPA
 * ♦ Categories of Data Collected
 * ♦ What Personal Data did we disclose for a business purpose?
 * ♦ What Personal Data did we sell?
 * ♦ What sources did we obtain Personal Data from and for what other reasons
   did we collect it?
 * ♦ Your Rights and Our Obligations Under Nevada Privacy Law
 * ♦ Your Rights and Our Obligations under the GDPR
 * ♦ Our Collection, Use, and Sharing Practice
 * ♦ Legal Basis for Processing Your Personal Data
 * ♦ Exercising Your Rights
 * ♦ Lodging a Complaint
 * ♦ Retaining Your Personal data
 * ♦ Cross-Border Data Transfer

❖ Changes To This Privacy Statement
❖ How To Contact Our Privacy Office



PRIVACY AND DATA SECURITY STATEMENT



Thank you for visiting Slashdot Media’s online and mobile resources, and for
viewing this privacy and data security statement. Our full privacy statement,
contained in the pages that follow, serves to give notice about the types of
personal data we collect, how we use it, who we share it with and why, and what
we do to try to protect it. We encourage you to read our full statement
carefully.


 * YOUR PRIVACY CHOICES AND RIGHTS

You do not have to provide personal data to enjoy most of the features of our
online and mobile resources. Moreover, you can opt out of certain activities
like newsletters and announcements. You can learn more about that here.

This privacy statement was amended as of January 1, 2023 and is effective as of
that date. The English language version of this privacy statement is the
controlling version regardless of any translation you may attempt.


SOME IMPORTANT VOCABULARY

Although not itself a contract, this privacy statement is an important document
that explains how we address some of our legal obligations, and your related
legal rights, involving personal data. Clarity is, therefore, important. We will
use this section to let you know about some words that have special meanings
whenever you see them in this statement.

Let’s start with the word "statement" itself: when we reference "this
statement", "this privacy statement" and "our statement", we mean the Privacy
and Data Security Statement you are reading now. Wherever we say "Company, "we",
"us", our, or "SDM", we mean Slashdot Media LLC and the various websites that we
own and operate linked to this statement. We use the words "you" and your to
mean you, the reader, and other visitors to our online and mobile resources who
are, in all cases, over the age of 18. This age requirement is discussed in more
detail later in this statement here.

When we talk about our "online and mobile resources", we mean all websites,
portals, or other features SDM operates, as well as the mobile apps we’ve
created and distributed to let you interact with the content we provide. Those
online and mobile resources include, and this statement covers,
SlashdotMedia.com, SourceForge.net, Slashdot.org, wirefly.com, myrateplan.com,
voipreview.org, linuxjournal.com and tmonews.com. SDM also offers certain
business-to-business marketing and advertising services. When we refer to "lead
ads and content" we mean the special types of advertisements and other content,
such as whitepapers and email contents, containing forms or other means for
users to provide information showing their interest in the applicable product or
service. We do our best to make sure each of our online and mobile resources, as
well as lead ads and content, link to this statement. In referring to an
"affinity action" it means when you "follow" us, "like" us or take a similar or
analogous action on our external social media presence.

Finally, and perhaps most importantly, when we refer to "personal data", we mean
any information, data or data element, whether in electronic or other form,
that, alone or in combination with other elements, can be used to distinguish,
trace, or discover your identity. Certain data privacy laws include specific
elements or defined terms for what they consider to be the personal data (or
personal information) they govern. Where such data privacy laws apply, then the
term "personal data" includes the specific elements and defined terms required
by such laws.


WHO DO WE COLLECT PERSONAL DATA FROM?

We collect personal data from the following groups of data subjects:

 * visitors to, users of, and those that interact with our online and mobile
   resources ads and content ("Visitors and Users")
 * customers of our advertising marketing and lead generation services
   ("Customers")
 * members of our workforce and those who apply for posted jobs ("Our Workforce
   and Job Applicants")
 * our third-party vendors and business partners ("Vendors and Business
   Partners")

The categories of data we collect from each of these groups, and the ways in
which we use it, differs.

OUR VISITORS AND USERS

This privacy statement applies only to Visitors and Users of our online and
mobile resources and those that interact with our lead generation ads and
content including content we may send as part of email campaigns. Thus, the
words "you" and "your" throughout this privacy statement mean only those
categories of data subjects. In the case of Comprehensive Privacy Laws, "you"
and "your" are further defined below in relation to those laws.

OUR CUSTOMERS

Our customers enter into contracts with us. That contract is separate from this
statement and has its own terms and conditions for notice of collection of
personal data and governing our overall confidentiality, data privacy and data
security obligations. As a result, those terms, and not this statement, apply to
the personal data of customers.

OUR WORKFORCE AND JOB APPLICANTS

We collect and retain the types of professional or employment related personal
data you would expect an employer to have about its workforce and job
applicants. We provide legally required notices of collection and describe our
use and sharing of the personal data of our workforce and applicants in greater
detail in confidential internal human resource manuals and documents accessible
to members of our workforce.

OUR VENDORS AND BUSINESS PARTNERS

Like all corporate enterprises, we buy goods and services, lease equipment and
office space and attend industry events. In doing so, we interact with existing
and potential vendors and business partners from whom we necessarily collect
certain personal data. We describe our use of vendor and business partner
personal data in greater detail in our confidential contracts with those
parties.


WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

We collect personal data in three ways: (i) personal data you voluntarily
provide to us; (ii) personal data we collect through automated/technical means;
and (iii) personal data that you have previously made available publicly or to
other sources. We describe that type of voluntary submission and automatic
collection in the tables below. By using our online and mobile resources, you
are signifying to us that you agree with this section of our privacy statement
and that we may use and disclose your data as described.

VOLUNTARILY SUBMITTED DATA

If you choose to participate in or make use of certain activities and features
available via our online and mobile resources, you will need to provide us with
data about yourself. The types of personal data you will be submitting to us in
those situations is almost always limited to basic identifiers such as your
name, email address, mailing address and phone number. Below are some of the
ways you voluntarily give us your personal data:


DATA WE COLLECT VOLUNTARILY PROVIDED BY YOU WHEN YOU REGISTER ON OUR SITE, FILL
OUT A FORM, WRITE A REVIEW, WRITE A COMMENT, INTERACT WITH WEBSITE TOOLS, UPLOAD
IMAGES OR CONTENT, E-MAIL US OR SUBSCRIBE TO ONE OF OUR EMAIL LISTS. THIS DATA
IS DIRECTLY PROVIDED BY YOU.

Categories of data we collect voluntarily from you include:

 * If you register as a user, we collect personal data such as your full name,
   business or personal email address, job title, the name of your company,
   industry sector, and your telephone number;
 * Other information and data you may provide when writing a review, submitting
   a forum or blog post, submitting a comment, submitting a support or bug
   ticket, editing a wiki, uploading files or images, open-source code, or
   inbound emailing to an open-source project list.
 * Other data you provide when you communicate with us including your full name,
   contact details and business email address, phone number and details of any
   such communications.

We use this data for certain activities, including:

 * Verifying the validity of your review(s) and ensuring that false, misleading
   or malicious reviews are not posted:
 * Sending you email including, but not limited to service announcements,
   account related messages, project related updates, subscribed newsletters;
 * Sending marketing information and offers to business contacts regarding
   Slashdot Media services;
 * Inviting you to provide reviews about other products and services, and to
   consider other services provided by Slashdot Media;
 * Providing our services, managing our website, responding to your questions,
   investigating any complaints, and providing customer service;
 * Customize your digital markets experience;
 * Resolving disputes;
 * For internal analytical and research purposes to help us to measure interest
   in and improve our services;
 * Preventing prohibited or illegal activities;
 * Enforcing our policies.

We use this data because:

 * We have a legitimate business interest to:
 * * Manage and promote our business and brand;
   * Provide and improve our services;
   * Operate our business;
   * Improve the performance and user experience of our websites;
   * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Resolve any concerns or disputes you may have

AUTOMATICALLY COLLECTED DATA

When you visit our sites or use our online and mobile resources, basic data
about your internet/electronic activity is automatically collected through your
browser via tracking technologies, such as “cookies.” As just about everyone
knows by now, cookies are small text files downloaded onto your computer or
mobile device. Cookies allow us to collect your IP address and recognize your
computer or mobile device and store some data about your preferences for using
our online and mobile resources or past actions, such as described in the table
below:


DATA WE COLLECT ABOUT YOUR USE OF OUR WEBSITE AND APPS (AUTOMATICALLY
COLLECTED).

Categories of data we collect automatically about you include:

 * Data recorded in our logs, including URL, IP address, browser & OS data,
   timestamp, referring site, geolocation, and other standard browser data;
 * Behavioral data (such as data on the behavior or presumed interests of
   individuals which are linked to those individuals and may be used to create a
   user profile) pages viewed, images viewed, documents downloaded and links to
   other sites followed;
 * Data captured by our cookies (see our Cookie Policy).

We use this data for certain activities, including:

 * To personalize your experience on our website;
 * Operating our website, developing, and improving our products and services;
 * Analytical, statistical and trend analysis to improve the user experience and
   performance of our website;
 * Facilitate your access to and use of our website;
 * Resolving disputes and troubleshooting problems.

We use this data because:

 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
 * * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Improve the performance and user experience of our websites;
   * Develop our product and service offerings for service users.
   * you have given us your consent (where required under applicable law) to use
     your data for marketing. Where we rely on your consent, you have the right
     to withdraw this consent by contacting us using the information above or
     unsubscribing via the opt-out functionality provided in our marketing
     communications to you
   * Resolve any concerns or disputes you may have.



DATA PROVIDED BY YOU DIRECTLY THAT WE COLLECT WHEN YOU:

 * Create or claim a free or paid listing
 * Connect with Slashdot Media sales representatives
 * Register for an account with us
 * Correspond with us (either by phone or email)

Categories of data we collect automatically about you include:

 * Personal data such as your full name and contact details such as the name of
   your company, the state/county in which you are based, business email
   address, your telephone number and job title;
 * Your company website URL;
 * What you are interested in hearing about (e.g., lead generation or website
   review);
 * What advertising channels you use such as pay per click, pay per view, fixed
   or other advertising channels;
 * Data about the software you offer, e.g., the product name, type of software
   and product description;
 * Data we require so we may invoice you, including your payment details and
   billing data; and Other data you provide when you communicate with us,
   including your full name, contact details and business email address, phone
   number and details of our communications.

We use this data for certain activities, including:

 * Fulfilling your requests, for example, to publish your listing and other
   submitted content, to provide you with details of leads (including their
   name, data about their business, software requirements and follow up next
   steps (e.g., request demo), and to invoice you appropriately;
 * Managing your profile and listings;
 * Sending you service emails (e.g., service announcements and messages relating
   to your account);
 * Providing consultation services;
 * Notifying you about special offers available from us, our affiliates or
   partners, which may be of interest to you;
 * Sending marketing to business contacts regarding our services and products
   which may be of interest and to promote our business and brand;
 * Administering our services and website, investigating any complaints and
   providing customer service;
 * Responding to your questions and requests and otherwise customize your
   digital markets experience;
 * Resolving disputes;
 * For internal analysis and research to help us to measure interest in and
   improve our services;
 * Preventing prohibited or illegal activities;
 * Enforcing our policies.

We use this data because:

 * We have a legitimate business interest to:
 * * Manage and promote our business and brand;
   * Provide and improve our services;
   * Operate our business;
   * Obtain payment for our services;
   * Improve the performance and user experience of our websites;
   * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Resolve any concerns or disputes you may have.
 * We have collected your consent (where required under applicable law) to use
   your data for marketing. Where we rely upon your consent, you have the right
   to withdraw this consent by contacting the Data Protection Officer on the
   contact details above or unsubscribing via the opt-out functionality provided
   in our marketing communications to you.

If you prefer, we not receive the above-described personal data, please do not
submit it. This means you should not participate in the applicable activities on
or use the applicable features available from our online and mobile resources.
Such participation and use are strictly your choice. By not participating, you
may limit your ability to take full advantage of the online and mobile
resources, but most of the content in our online and mobile resources will still
be available to you.

Additional data about cookies and tracking technologies is available here.

If you access our online and mobile resources from a phone or other mobile
device, the mobile services provider may transmit to us certain data such as
uniquely identifiable mobile device data. That, in turn, allows us to collect
mobile phone numbers and associate them with the mobile device identification
data. Some mobile phone service providers also operate systems that pinpoint the
physical location of devices, and we may receive this geolocation data as well.

When you use our online and mobile resources, we may allow third party service
providers to place their own cookies or similar technologies to engage in the
same types of collection we describe above.

Finally, there is a category of personal data we may collect that does not fit
neatly into the “voluntarily submitted” or “automatically collected” categories.
If you use both our app and a third party mail service (such as Google’s Gmail,
Yahoo! Mail and the like) on your mobile device, you may have activated a
setting that allows us to use certain technologies such as application
programming interfaces, to automatically access (sometimes referred to as
“parse”) your mail as it relates to your use of our app. If you did activate the
setting allowing us to do so, our use of any data we receive from those
technologies will adhere to the requirements of the publisher of the applicable
technology. This includes, if we use Google APIs, adhering to the Google API
Services User Data Policy and its Limited Use requirements.

DATA COLLECTED FROM OTHER SOURCES

As part of our services, we will sometimes initially identify prospective
customers via public websites or applications operated by third parties such as
Seamless.ai. The type of data we collect is the same as that described above,
such as name, email address, mailing address and phone number, as well as
potentially workplace and job title. We purchase data sets from third parties
and use them to check the accuracy of the data we collected from such public
sources. In some cases, we may use the data we purchased from a third party even
if we did not previously collect it from a public source. We exercise reasonable
care and due diligence in purchasing data from third parties and only do so when
we are able to obtain assurances that they obtained personal data in a lawful
manner.

USER BEWARE: EXTERNAL SITES, APPS, LINKS AND SOCIAL MEDIA

We maintain a presence on one or more external social media platforms such as
Twitter, Facebook, Instagram, and LinkedIn. We may further allow the community
features of our online and mobile resources to connect with, or be viewable
from, that external social media presence. Similarly, our online and mobile
resources may contain links to other websites or apps controlled by third
parties.

We are not responsible for the content on, or the privacy practices of, social
media platforms, or any third-party sites or apps to which we link. Those apps,
sites and platforms are not controlled by us and therefore have their own
privacy policies and terms of use. To be clear: neither this statement nor the
terms of use appearing on or in any of our online and mobile resources apply to
our social media presence or any third-party sites or apps to which we may link.
That means even if you take an affinity action on our specific social media
profile, and identifiers about you are automatically collected and given to us
as a result, that collection and transfer is governed by the privacy policies
and other terms of the applicable social media platform and are not our
responsibility. If you have questions about how those apps, sites and platforms
collect and use personal data, you should carefully read their privacy policies
and contact them using the data they provide.


HOW DO WE USE THE PERSONAL DATA WE COLLECT?

We use the personal data we collect only in the manner and through the means
allowed by applicable law. That means we determine whether we have a lawful
basis/legitimate business purpose to use your personal data before doing so. As
stated in applicable law, such lawful bases/legitimate business purposes may
include receiving express consent, operating our business, performing a
contract, and complying with a legal obligation. More specifically, we use the
personal data as follows:

We use the automatically collected personal data described here to compile
generic reports about popular pages/features of our online and mobile resources,
and to see how users are accessing our online and mobile resources and, in some
cases, (such as affinity actions) send materials to you. We use the personal
data you voluntarily submitted, as described here, to respond back directly to
you and/or send you the data you requested or about which you inquired. We also
may use any such personal data you provide to customize our programs and
newsletters to make them more relevant to you. We use the personal data that we
collect from other sources to contact prospective customers and provide them
with details regarding our services. In limited cases we do sell personal data
which you voluntarily provide when using our online and mobile resources. We
describe those cases in this section.

We use and retain your personal data in accordance with applicable law and only
as long as necessary to carry out the purposes described above in accordance
with our internal data retention procedures.


HOW LONG DO WE KEEP YOUR PERSONAL DATA

We retain your personal data for a period of time consistent with the purpose of
collection and processing, required to fulfill our legal obligations and for
enforcing our agreements. The retention period for personal data is determined
by us based on the amount, nature, and sensitivity of the personal data being
processed, the potential risk of harm from unauthorized use or disclosure of the
personal data, whether we can achieve the purposes of the processing through
other means, and any applicable legal requirements. For example, we will retain
certain identifiers for as long as it is necessary to continue maintaining your
account and providing you our products and services, to comply with our tax,
accounting, and recordkeeping obligations, to administer certain warranties, and
for research, development, and safety purposes, as well as an additional period
as necessary to protect, defend, or establish our rights, defend against
potential claims, and to comply with our legal obligations. Typically, after
expiry of the applicable retention periods, your personal data will be deleted,
unless such deletion is rendered impractical or unreasonably burdensome due
technical or other reasons, including where it becomes technically impossible,
data retained as part of automatic archiving and back-up procedures, In such
cases where any information is retained, We will implement appropriate measures
designed to prevent misuse of such data. In certain circumstances, we may
anonymize your personal data so that it can no longer be associated with you, in
which case we may use such data without further notice to you.


WHEN/WITH WHOM DO WE SHARE PERSONAL DATA?

We may share your personal data as described below. This sharing applies to the
personal data of all four groups of data subjects.

AFFILIATES

We may share personal data with other corporate affiliates who will use such
data in the same way as we can under this statement.

LEGAL REQUIREMENTS

We may disclose personal data to government authorities, and to other third
parties when compelled to do so by such government authorities, or at our
discretion or otherwise as required or permitted by law, including responding to
court orders and subpoenas.

TO PREVENT HARM

We also may disclose such data when we have reason to believe that someone is
causing injury to or interference with our rights or property or harming or
potentially harming other persons or property.

BUSINESS SALE/PURCHASE

If we, or any of our affiliates, sell or transfer all or substantially all of
our assets, equity interests or securities, or are acquired by one or more third
parties as a result of an acquisition, merger, sale, reorganization,
divestiture, consolidation, or liquidation, personal data may be one of the
transferred assets.

VENDORS AND BUSINESS PARTNERS

We also share personal data with those of our vendors and business partners who
need it to perform under the contracts we have with them. As part of our
Security Program, we have adopted standards for those vendors and business
partners who receive personal data from us. We attempt to bind such vendors and
business partners to those standards via written contracts. Such standards
include expectations that when we share personal data with our vendors and
business partners, they will comply with all applicable privacy and data
security laws and regulations and our Security Program and will contractually
require and cause their subcontractors and agents to do the same

For any personal data, our vendors and business partners process or store at
their own locations, we further expect them to use technology infrastructure
meeting, at least at the facilities level, minimum recognized standards for
security controls. Such recognized standards include those published by the
International Standards Organization, the National Institute of Standards and
Technology or any reasonably equivalent standards.

Please note, however, that we cannot guarantee that all our vendors and business
partners will agree to the above-described contractual requirements; nor can we
ensure that, even when they do agree, they will always fully comply.


HOW LONG DO WE KEEP YOUR PERSONAL DATA

OUR DATA SECURITY PROGRAM

We have adopted, implemented, and maintain an enterprise-wide corporate data
security and privacy program that includes technical, organizational,
administrative, and other security measures designed to protect, as required by
applicable law, against reasonably anticipated or actual threats to the security
of your personal data (the "Security Program"). Our Security Program was created
with reference to widely recognized industry standards such as those published
by the International Standards Organization and the National Institute of
Standards and Technology. It includes, among many other things, procedures for
assessing the need for and employing encryption and multi-factor authentication
as appropriate or using equivalent compensating controls. We therefore have
every reason to believe our Security Program is reasonable and appropriate for
our business and the nature of foreseeable risks to the personal data we
collect. We further periodically review and update our Security Program,
including as required by applicable law.

OUR INCIDENT RESPONSE AND MANAGEMENT PLAN

Despite the significant investment we’ve made in, and our commitment to, the
Security Program including enforcement of our third party oversight procedures,
we cannot guarantee that your personal data, whether during transmission or
while stored on our systems, otherwise in our care, or the care of our vendors
and business partners, will be free from either failed or successful attempts at
unauthorized access or that loss or accidental destruction will never occur.
Except for our duty under applicable law to maintain the Security Program, we
necessarily disclaim, to the maximum extent the law allows any other liability
for any such theft or loss of, unauthorized access or damage to, or interception
of any data or communications including personal data.

All that said, as part of our Security Program, we have specific incident
response and management procedures that are activated whenever we become aware
that your personal data was likely to have been compromised. Those procedures
include mechanisms to provide, when circumstances and/or our legal obligations
warrant, notice to all affected data subjects within the timeframes required by
law, as well as to give them such other mitigation and protection services (such
as the credit monitoring and identity theft insurance) as may be required by
applicable law. We further require, as part of our vendor and business partner
oversight procedures, that such parties notify us at least within the timeframes
required by law if they have any reason to believe that an incident adversely
affecting personal data we provided to them has occurred.


YOUR GENERAL RIGHTS AND OPTIONS

If we are using your personal data to send you marketing materials, such as
newsletters or product alerts via text or email, you may opt out by following
the opt-out instructions linked or otherwise provided in the applicable email or
other communication (e.g., by responding to the text with “STOP”). In addition,
certain of our online and mobile resources will provide a centralized opt-out
link allowing you to opt out of any programs in which you may have enrolled
using that online and mobile resource. When we receive your request, we will
take reasonable steps to remove your name from our distribution lists, but it
may take time to do so. You may still receive materials for a period of time
after you opt out. Opting out of or changing affinity actions or other
submissions or requests made on our external social media presence, require that
you do so directly on that applicable platform as we do not control their
procedures.

Some browsers have a do not track (“DNT”) feature that lets you tell websites
that you do not want to have your online activities tracked. We do not support
DNT. We do support Global Privacy Control ("GPC") in jurisdictions that require
it such as California. The GPC signal communicates a Do Not Sell request from a
global privacy control, as per CCPA-REGULATIONS §999.315 if enabled for that
browser or device, or, the data subject if they can be identified.

You also have additional rights under certain laws to withdraw consent and to
instruct us not to sell your personal data. We describe those rights and the
procedure for exercising them here.


CHILDREN’S PRIVACY

Federal law imposes special restrictions and obligations on commercial website
operators who direct their operations toward and collect and use /data from
children under the age of 13. We take those age-related requirements very
seriously, and, consistent with them, do not intend for our online and mobile
resources to be used by children under the age of 18, and certainly not by those
under the age of 13. Moreover, we do not knowingly collect personal data from
minors under the age of 18. If we become aware that anyone under the age of 18
has submitted personal data to us via our online and mobile resources, we will
delete that data and not use it for any purpose whatsoever. We encourage parents
and legal guardians to talk with their children about the potential risks of
providing personal data over the Internet.


COMPREHENSIVE PRIVACY LAWS

Privacy and data protection laws vary around the world and among the individual
United States. Our obligations arising under the majority of the world’s privacy
laws, including U.S. federal and most state laws, are satisfied by individual
risk assessments that we conduct to ensure we act reasonably and responsibly
when processing your personal data. In some jurisdictions, however, privacy laws
grant you, the data subject, certain specific rights regarding your personal
data. We refer to these types of privacy laws as "Comprehensive Privacy Laws."
Examples of Comprehensive Privacy Laws include the European Union ("EU GDPR"),
and United Kingdom’s ("UK GDPR") variants of the General Data Protection
Regulation (collectively, the "GDPR"), and the consumer privacy statutes of
several U.S. states, such as California, Colorado, Utah, and Virginia. In other
jurisdictions, such as Nevada, privacy laws have some features of Comprehensive
Privacy Laws such as the right to opt-out of the sale of your personal data.

The nature and locations of our business activities make us subject to some,
though not necessarily all, Comprehensive Privacy Laws. We are for instance,
subject to the California Consumer Privacy Act, or "CCPA" and the GDPR. As such,
when we collect personal data from data subjects protected by the CCPA or GDPR,
we become subject to, and those data subjects have rights under, those
Comprehensive Privacy Laws. This section of our statement is used to explain
your rights under those laws. For purposes of this section, the words "you" and
"your" mean only California consumers (as defined by CCPA) and data subjects
whose personal data was collected while they were in a GDPR jurisdiction.

Questions about how the Comprehensive Privacy Laws of other jurisdictions might
apply to us can be directed to us through the contact data found here.

YOUR RIGHTS AND OUR OBLIGATIONS UNDER THE CCPA

CATEGORIES OF DATA COLLECTED

We collected the following categories of personal data within the last 12
months:

 * identifiers such as name, address, IP address, and other similar identifiers
 * personal data under the Customer Records provision of the California Civil
   Code such as a name, address, telephone number, credit card number
 * commercial data such as products or services purchased
 * biometric data such as fingerprints or facial or retina scans
 * internet/electronic activity such as browsing history and search history
 * geolocation data including geographic coordinates/physical location
 * audio, video, electronic or other similar data
 * professional or employment related data such as job history and performance
   evaluations
 * Education data
 * inferences drawn from the foregoing to create a profile about a consumer
   reflecting the consumer’s preferences, characteristics, psychological traits,
   predispositions, behavior, attitudes, intelligence abilities and aptitudes.

WHAT PERSONAL DATA DID WE DISCLOSE FOR A BUSINESS PURPOSE?

We may have disclosed the categories of personal data listed above for one or
more business purposes permitted by the CCPA during the last 12 months.

WHAT PERSONAL DATA DID WE SELL?

As a data-driven business-to-business demand generation marketing and technology
company, we provide services to help our customers understand and expand their
audiences such as email marketing, lead generation and advertising. As part of
those services, we collect certain personal data that is then sold as part of
our broader service offerings. In almost all cases, only a name, email address,
work title and location and a phone number will be sold. When we collect
personal data intended for sale, we provide you with a mechanism to
affirmatively consent at the time of collection. You can later withdraw that
consent, and otherwise instruct us not to sell, or further sell your data at any
time by visiting our opt-out/do not sell portal found here.

WHAT SOURCES DID WE OBTAIN PERSONAL DATA FROM AND FOR WHAT OTHER REASONS DID WE
COLLECT IT?

Please re-review this part of this privacy statement to understand the scope of
purposes and the sources from which we collect it. Similarly, we urge you to
re-read this part of this statement where we describe the categories of third
parties with which we may share your personal data and why.

RIGHTS TO KNOW AND ACCESS

California residents have the following rights under the CCPA. If you exercise
these rights, we will not discriminate against you by treating you differently
from other California residents who use our sites and mobile resources or
purchase our services but did not exercise their rights.

 * Know – You have the right to request that we disclose to you, specifically
   beyond the general statement immediately above, the categories and specific
   elements of personal data collected including the source of the data, our use
   of it and, if the data was disclosed or sold to third parties, the categories
   so disclosed or sold as well as the categories of third party who received or
   purchased it.
 * Access – You have the right to receive a copy of the categories and specific
   elements of personal data we collected about you in the preceding 12 months.
 * Correct – You have the right to request the correction of inaccurate
   information collected.
 * Delete – You the right to request the deletion of personal data We collected
   about you held by Us, Our service providers, contractors or any other third
   party We have disclosed your personal data to under certain circumstances.
 * Opt Out – You have the right to opt out of any sale or sharing of personal
   data (as defined in the CCPA) if such sale or sharing occurs.
 * Transfer – You have the right to request the transfer of specific pieces of
   information We have collected about you to another entity.
 * Sensitive Information – The right to limit the disclosure of sensitive
   personal data in specific instances as set forth in the CCPA.

We support Global Privacy Control “(GPC”). The GPC signal communicates an
Opt-Out/Do Not Sell request from a global privacy control, as per
CCPA-REGULATIONS §999.315 if enabled for that browser or device, or, the data
subject if they can be identified. If you opt-out using the GPC functionality
available in some browsers while you are logged in to one of our sites or
portals, we will use that signal to opt you out of all online and offline
marketing and sharing. If your browser functionality supports GPC but you are
not logged into one of our sites or portals we will use that signal to opt you
out of online tracking only. If your browser does not support GPC you can click
on the Do Not Sell link at the bottom of our site to activate our cookie manager
where you can select your opt out choices for browser activity. If you email or
write to us with an opt out request, we will use that request to opt you out of
all offline based marketing and sharing and any online based marketing and
sharing when you are logged into your account in one of our sites or portals.

In addition to the rights described above, you, or an authorized agent acting on
your behalf, can exercise the Right to Know up to two different times every 12
months. To exercise these rights, you or your agent must contact us via any of
the four means listed here. We may ask you to fill out a request form. The CCPA
only allows us to act on your request if we can verify your identity and/or your
agent’s authority to make the request, so you will also need to follow our
instructions for identity verification. If you make a verifiable request per the
above, we will confirm our receipt and respond in the time frames prescribed by
the CCPA.

YOUR RIGHTS AND OUR OBLIGATIONS UNDER NEVADA PRIVACY LAW

If you are Nevada resident, Nevada law (SB 220), entitles you to opt out of the
sale of certain kinds of personal data. A sale under Nevada law is the transfer
of this personal data to third parties for monetary consideration. If you are a
Nevada resident and wish to opt-out, you may do so by contacting us at any of
the 4 methods here or click on the Opt-Out link at the bottom of our site

YOUR RIGHTS AND OUR OBLIGATIONS UNDER THE GDPR

When we collect personal data from individuals located in the European Economic
Area and the United Kingdom (the "GDPR Jurisdictions"), those individuals have
rights under the GDPR. This section of our statement is used to fulfill our GDPR
obligations and explain your GDPR rights. For purposes of this section, the
words "you" and "your" mean only such individuals located in the GDPR
Jurisdictions.

OUR COLLECTION, USE, AND SHARING PRACTICES

Please review this section to understand the scope of purposes and the sources
from which we collect personal data. Similarly, you can find data about the
categories of third parties with which we may share your personal data and why
we share it in this section. We do not use your personal data for automated
decision-making. We do, however, collect certain personal data for the purpose
of selling it as described here. We also purchase certain personal data from
third parties. If we are reasonably aware that such third parties have not
provided you with appropriate notice of collection as required under GDPR
Article 13, we will provide you the required alternate notice under Article 14
when we first contact you using such data. We typically provide that Article 14
notice in the body of the communication used to contact you.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Our legal basis for collecting and using your personal data will depend on the
personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data where the processing is in our
legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms, such as to contact you about products and
services you may be interested in. In certain circumstances where our legal
basis of processing is for performance of a contract with you, please be aware
that, in those circumstances, where you do not provide personal data, which is
required by us, we will not be able to provide the products and services under
our contract with you or may not be able to comply with a legal obligation on
us. In some cases, we may also have a legal obligation to collect personal data
from you or may otherwise need the personal data to protect your vital interests
or those of another person. If we happen to obtain your consent to process your
personal data, you may withdraw your consent at any time via any of the means
listed here.

EXERCISING YOUR RIGHTS

You may exercise the rights available to you under the GDPR, including the right
to object to the processing of your personal data, as follows:

 * Access – the right to obtain a confirmation that your personal data is being
   processed, access to your personal data (if we are in fact processing it),
   other data about the processing of your personal data (most of which is set
   forth in this statement) and a copy of the personal data we are processing.
 * Rectification – the right to have your personal data corrected if it is
   inaccurate, and depending on the purposes of processing, you may also have
   incomplete personal data completed.
 * Erasure – also known as the "right to be forgotten", the right to request
   your personal data be deleted under certain circumstances such as if it is no
   longer needed for the original purpose it was collected for or if you
   withdrew your consent. The right of erasure does not apply under limited
   circumstances including if the processing is necessary for exercising the
   right of freedom of expression and data or our compliance with a legal
   obligation.
 * Restrict processing – the right to restrict processing of your personal data
   under certain circumstances such as if you contest the accuracy of the
   personal data (and only for so long as it takes to verify that accuracy), the
   processing is unlawful and you have requested restricting the processing
   rather than erasure, or if we no longer need the personal data but you need
   it to establish, exercise or defend a legal claim.
 * Portability – the right to receive the personal data you provided to us (and
   not any other data) under limited circumstances such as if the basis for
   processing the personal data was consent or necessary for the performance of
   a contract with you, or the processing is carried out by automated means.
 * Automated Processing – the right to not be subject to a decision based solely
   on automated processing, including profiling.
 * Object to processing – the right to object to the processing of your personal
   data under the following circumstances:
   * Legitimate Interests – if the basis for which the processing occurs is in
     our legitimate interests or in the performance of a task carried out in the
     public interest. If you object, we will stop processing your personal data
     unless we can demonstrate compelling legitimate grounds for the processing
     which override your interests, rights and freedoms or we require the
     personal data to establish, exercise or defend a legal claim.
   * Direct Marketing – if the processing is for direct marketing purposes.

You can exercise these rights by contacting us using the contact data listed
here, however, we may need to request additional data from you to verify your
identity before granting your request. We will respond to all requests we
receive from individuals wishing to exercise such rights in accordance with the
GDPR. We have the ability to charge a reasonable fee for administrative costs of
providing the personal data to you in situations where the request is unfounded
or excessive (due to its repeated nature), or in the alternative, we may refuse
to act on the request in those situations

LODGING A COMPLAINT

You have the right to complain to your data protection authority about our
collection and use of your personal data. Please contact your local data
protection authority for more data. Contact data for data protection authorities
can be found here and here.

RETAINING YOUR PERSONAL DATA

We will store and retain your personal data in accordance with applicable law
and as long as necessary to carry out the purposes described in this Section in
accordance with our internal data retention procedures. The criteria used to
determine the retention periods include:

 * how long the personal data is needed in connection with the applicable
   purposes for which we use it;
 * the type of personal data collected
 * whether we are subject to a legal, contractual, or similar obligation to
   retain the personal data (e.g., mandatory data retention laws, government
   orders to preserve personal data relevant to an investigation, or personal
   data that must be retained for the purposes of litigation or disputes).

CROSS-BORDER DATA TRANSFER

By submitting personal data to us, we will, receive it in the United States
where our technical infrastructure resides. We undertake such collection solely
for the purposes described previously in this statement but note that such
direct collection does not constitute a “transfer” under the GDPR. In certain
instances, we collect personal data from data subjects located within the GDPR
Jurisdictions, and do then transfer it to the U.S., to international
organizations, and/or to third countries for the same purposes discussed above.
When doing so, may use the mechanisms prescribed for lawful transfers in GDPR
Articles 44 through 49, including, where appropriate, then-current standard
contractual clauses or similar mechanism appropriate to the particular GDPR
Jurisdiction involved. you can request further details in relation to
international transfers, including a copy of the standard contractual clauses,
by contacting us here.


CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to change or update this statement from time to time.
Please check our online and mobile resources periodically for such changes since
all data collected is subject to the statement in place at the time of
collection. Typically, we will indicate the effective/amendment date at the
beginning of this statement. If we feel it is appropriate, or if the law
requires, we will also provide a summary of changes we have made near the end of
the new statement.


HOW TO CONTACT OUR PRIVACY OFFICE

If you have any questions about our privacy and data security policies,
procedures, and practices, including anything we say in this privacy statement,
we encourage you to contact our Privacy Office.

Slashdot Media, LLC

 * Address: PO Box 12190 San Diego, CA 92122
 * Attn: Privacy Compliance
 * Phone: 1-800-552-9000
 * Slashdot Media Privacy Portal:
    * Info Request and Data Deletion
    * Do Not Sell My Personal Information

 * Email: privacy@slashdotmedia.com



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