Privacy Policy

Protecting your private information is our priority.

STRATEGIC MEDIA 21, INC. EU PRIVACY POLICY

Contents

1. Background
2. What is your personal information and what types of personal information about you do we process?
3. What is the source of your personal information?
4. What do we use your personal data for?
5. What are the legal grounds for our processing of your personal information (including when we share it with others)?
6. When do we share your personal information with other organizations?
7. How and when can you withdraw your consent?
8. Is your personal information transferred outside the UK or the EEA?
9. What should you do if your personal information changes?
10. Do you have to provide your personal information to us?
11. Data Security
12. For how long is your personal information retained by us?
13. What are your rights under data protection laws?
14. Glossary

Strategic Media 21, Inc. (SM21) is committed to protecting your personal data and we respect your privacy. This privacy policy will let you know how we work with your personal data when you visit our websites, and this policy will discuss your privacy rights and how the law protects you.

So that you can be fully informed about how and why where using your data, it is important that you review this notice along with any other privacy notices or fair processing notices we may provide when we are processing your personal data. This privacy notice supplements other notices and does not intend to replace them.

Click through the sections below to learn more, and use the Glossary to understand the meaning of some of the terms of this policy.

1. Background

This privacy policy will tell you how SM21 collects and processes your personal data when you use the website, including data you might provide us during your use.

SM21 does not knowingly collect data relating to children, as our website is not intended for use by children. Children under 13 years old are not the target audience of this site. By making this site available to the public, we do not intend to solicit personal information from these children. If you are under the age of 13, please do not provide any personal information about yourself to us.

Controller

Strategic Media 21, Inc. is a California corporation. When we mention “SM21” or “we” or “us” or “our” in this notice, we are referencing Strategic Media 21, Inc.

Strategic Media 21, Inc. is the controller and is responsible for this website and its compliance with regulations, including the General Data Protection Regulation. As controller, we will maintain a record of all processing activities for which we are responsible. Our company is acting as data protection officer (“DPO”) who is responsible for overseeing questions about this privacy notice. If you have any questions about this privacy notice, or wish to exercise any legal rights you have, please contact the DPO using the following details:

Full Name of Legal Entity: Strategic Media 21, Inc.
Name of DPO: Strategic Media 21, Inc.
Email address: contact@strategicmedia21.com
Postal address: 1825 Hamilton Ave. San Jose, CA 95125 Attn: Data Protection Officer

You have the right to make a complaint at any time to your supervisory authority. However, we would appreciate the chance to address your concerns before you do so, so please contact us first.

2. What is your personal information and what types of personal information about you do we process?

Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly. This might include name, identification number, location, etc. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, and gender.

• Contact Data includes email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, your interests, preferences and feedback.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not legally considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Third-party links - Note that SM21’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. What is the source of your personal information?

We use different methods to collect data from and about you, including:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or providing other information via our website. This includes personal data you provide when you use our website, request our services, subscribe to our publications, request marketing to be sent to you, or give us feedback.

Automated technologies or interactions. We may automatically collect Technical Data about your equipment, browsing actions and patterns when you interact with our website. We may collect this personal data by using cookies, server logs and/or will other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Technical Data from analytics providers or from our social media pages.

4. What do we use your personal data for?

We may collect, use, store and transfer different kinds of personal data about you for a variety of purposes:

Purpose/activity: To manage our relationship with you which includes notifying you about changes to our terms or privacy policy

Type of data: (a) identity(b) contact(c) profile(d) marketing and communications

Lawful basis for processing including basis of legitimate interest: (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)

Purpose/activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a) identity(b) contact(c) technical

Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation

Purpose/activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: (a) identity(b) contact(c) profile(d) usage(e) marketing and communications(f) technical

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how visitors use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/activity: To use data analytics to improve our website, products/services, marketing, user relationships and experiences

Type of data: (a) technical(b) usage

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/activity: To make suggestions and recommendations to you about services that may be of interest to you

Type of data: (a) identity(b) contact(c) technical(d) usage(e) profile

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (marketing purposes).

You may receive marketing communications from us if you have requested information from us or received services from us and you have not opted out of receiving that marketing.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform services to you through the website.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than when sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us: contact@strategicmedia21.com.

6. When do we share your personal information with other organizations?

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties, as defined in the Glossary.

• External Third Parties, as defined in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. How and when can you withdraw your consent?

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at contact@strategicmedia21.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provided to you. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before your withdrawal.

You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy for further details.

We will work to make sure that withdrawing your consent will be as simple as when you provided it.

8. Is your personal information transferred outside the UK or the EEA?

Sharing your personal data may involve transferring your data outside the European Economic Area (EEA). To ensure that your personal data is protected when transferred outside the EEA, a data transfer agreement will be put in place between SM21 and the other involved party incorporating the EU’s standard contractual clauses. Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. What should you do if your personal information changes?

It is important that personal data we hold about you is accurate. Please give keep us informed of your personal changes.

10. Do you have to provide your personal information to us?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform certain tasks (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you desire from us but we will notify you if this is the case at the time.

11. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost destroyed, damages, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

12. For how long is your personal information retained by us?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may make your personal data anonymous (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. What are your rights under data protection laws?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

If you wish to exercise any of the rights set out above, please contact us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you suffer damage as a result of our failure to comply with certain regulations, you may have the right to compensation.

14. Glossary

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

“Internal third parties” are other companies within SM21 acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.

“External third parties” are service providers acting as processors who provide IT and system administration services.

 

 

COOKIE POLICY

Strategic Media 21, Inc. ("us", "we", or "our") uses cookies to enhance your experience on our sites, and many of our web pages use "cookies". By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, and your choices regarding cookies.

What are cookies

Cookies are small text files that we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personal information unless you choose to provide this information to us by, for example, registering at one of our sites. Once you choose to provide a web page with personal information, this information may be linked to the data stored in the cookie. A cookie is like an identification card, and can be personal data. It is unique to your computer and can only be read by the server that gave it to you. A cookie file allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be "persistent" or "session" cookies.

How we use cookies

We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalize your experience on our web pages (e.g. to recognize you by name when you return to our site). We also may use cookies to offer you products and services.

Cookies save you time as they help us to remember who you are. Cookies help us to be more efficient. We can learn about what content is important to you and what is not. We can revise or remove web pages that are not of interest and focus our energies on content you want.

Your choices regarding cookies

By continuing to use our site, you accept our use of cookies and our revised Privacy Policy.

You can configure your browser to accept all cookies or to alert you every time a cookie is offered by a website's server. Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

We may also use small pieces of software code called "web beacons" or "clear gifs" to collect anonymous and aggregate advertising matrix, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image, called a single-pixel or clear GIF. Web beacons can recognize certain types of information on a user’s computer, such as a user's Cookie number, time and date of a page view, and description of the page where the web beacon is placed. You may render some web beacons unusable if you choose to reject their associated cookies. These web beacons may be used to deliver cookies that conform with our Cookie Policy.