Whilst we would love you to read this all, we thought we would highlight the main pointers from our Policy for you here.
- Yes, we secure all of the information you submit to us like it's our own. And we only ask you for information that is important to complete a payment, or to keep you up-to-date.
- We hate spam, and take data protection seriously. If you have any questions or concerns in this regard please contact -> [email protected]
A. COLLECTION OF INFORMATION
A.1 Information We Collect Automatically through the Services: In order to help provide recommendations and promoted content that is relevant to your interests, we automatically collect certain information when you access websites and mobile applications that incorporate the Services. This information reflects information about the websites you visit, the mobile applications you use, and how you interact with our Services.
A.2 Browser and Device Information: We collect information about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier, and identifiers assigned to your browser or device.
A.3 Usage Data: We collect information about the websites and mobile applications you visit that integrate our Services and about the websites that you visit immediately prior to visiting a website that integrates our Services, including the date and time your browser or device accesses such websites and the specific pages accessed.
A.4 Click Data: We collect information about the content and ads that you click on within the Services.
A.5 Information You Provide
- A.5.1 You may be able to customize your experience by logging in to SM network through a social media service. If you do this, we will have access to certain information from that service, such as your name, profile information, likes, shares, posts, etc., in accordance with the authorization procedures determined by the social media service you use to login.
- A.5.2 You also may be able to customize your SM experience by registering as a user directly on the Site and customizing your experience. If you do this, we will have access to the information you provide in doing so, including your name, contact information, and any preferences you select.
B. INFORMATION WE COLLECT FROM OTHER SOURCES
B.1 We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including our business partners, other advertising companies, and publicly available sources.
B.2 Cookies and Other Tracking Technologies We Use to Collect Information
C. USE OF INFORMATION
C.1 We use the information we collect to determine what content is most relevant to you, to disseminate recommendations and promoted content to you, and to understand, measure, and report on how users interact with the Services. We also use the information we collect from the Service to maintain and constantly improve upon the Services.
C.2 Sharing Information
- With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of SM or others;
- In connection with, or during negotiations of, any merger, sale of SM assets, financing or acquisition of all or a portion of our business by another company;
- Between and among SM and any current or future parent, subsidiary and/or affiliated SM; and
- With your consent or at your direction.
- C.2.2 We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share de-identified information with advertisers that partner with us to help them understand how well their advertisements performed.
D. YOUR CHOICES
D.1 Opting out of Personalized Content
D.1.1 You may opt out of receiving personalized content and advertisements from SM by sending us an email with the subject "Opt Out". When you opt out, we will set a cookie on your browser that tells us not to personalize recommendations or promoted content on that browser or to record information about the sites you are visiting. If you use multiple devices and/or multiple browsers, you need to opt out on each device and browser you use, even if you login to SM using a social media account.
D.1.2 Please note that even after you have opted out, you will still see SM recommendations and promoted content, but these recommendations and promoted content will not be personalized based on the sites you visit.
D.1.3 Note that if you clear your cookies, you may need to opt out again.
D.1.4 For information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes by companies that participate in the Digital Adverting Alliance, please visit www.aboutads.info/choices. If you are in the EU, you may opt out at the European Digital Advertising Alliance, http://www.youronlinechoices.eu/. Cookies
D.1.5 Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of some websites.
Right to withdraw consent.
D.1.6 When we rely on your consent for processing of your personal information, you have the right to withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of SM's processing based on consent before your withdrawal.
Right of access to and rectification of your personal information.
D.1.7 You have a right to request a copy of your Personal Information stored with SM. We will provide a copy to you against the payment of reasonable fee associated with gathering of the information (as permitted by law). We may limit or deny your request if providing you with a copy could adversely affects the rights and freedoms of others. You may also request us to correct or update any inaccurate personal information stored by us.
The right to be forgotten
D.1.8 You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented to, but no longer consent to; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. Your right to erasure is subject to limitations by relevant data protection law.
Right to data portability
D.1.9 If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have us transfer your personal information directly to another data controller, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
Right to restriction of processing
You have the right to restrict our processing of your personal information where one of the following applies:
a. You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
b. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
c. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise, or defend legal claims.
d. You have objected to processing, pending the verification of whether the legitimate grounds of SM's processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
E. INFORMATION COLLECTED ON OUR WEBSITE
E.1 Advertisers and publishers may provide contact information through our Site to find out more about SM be contacted by a SM representative, or to start working with SM. SM (and its agents and service providers) may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research.
E.2 We will also use the information we collect from advertisers and publishers for invoicing and billing purposes. We will not rent or sell this information to other companies. You may opt out of receiving promotional emails from SM by following the instructions in those emails or by emailing us at [email protected] If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
E.3 SM may also work with third parties that collect data on our Site and on other websites to serve you targeted ads. You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program by visiting about http://optout.aboutads.info/. If you are in the EU, you may opt out at the European Digital Advertising Alliance, http://www.youronlinechoices.eu/.
F.1 We store the information we collect for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
G. DATA TRANSFERS
G.1 SM is based in the United Kingdom. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
H. HOW WE PROTECT THE INFORMATION WE COLLECT
H.1 We take reasonable measures to help protect the information we collect from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet or electronic storage can be completely secure, so we cannot guarantee the absolute security of any data.
I. EEA RESIDENTS
I.1 If you are a resident of the European Economic Area ("EEA"), you have certain rights and protections under the law regarding the processing of your personal data.
I.2 Legal Basis for Processing
- I.2.1 If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
- We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data to provide content and advertisements that may be of interest to you, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
- There is another applicable lawful basis under which we are permitted to process your personal data.
I.3 Data Subject Requests
I.3.1 If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at [email protected]
I.4 Questions or Complaints
I.4.1 If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
J. CONTACT US
J.1 If you have any questions or need to contact us, please do so at [email protected] or at: 85 Great Portland Street, First Floor, London, England WIW 7LT.