Privacy Policy – Dean Media Group (“Dean Media Group,” “we,” “us” or the “Company”)

Last updated as of: 12.2012.

1. Overview.
This Privacy Policy sets forth our policy and practices with respect to the collection, retention, protection, use and destruction of any information, including personally identifiable information (“Personal Data” or “PI”) and non-personally identifiable information held by us.

We take the privacy of your Personal Data and other information extremely seriously.  We want you to know that we will take all commercially practicable and available precautions to ensure the security and privacy of your information.  We also want you to know what information we collect, why and how we will treat that information.  Finally, we want you to be able to exercise control over your data so that if you no longer wish to provide us information or want to opt-out of receiving certain communications, you can do that easily.  This Privacy Policy is for you.

This Privacy Policy applies to all business customers of our products and services and visitors to our websites, mobile sites, and mobile applications.  Please note that this Policy does not apply to visitors to our customers’ sites nor does it cover the practices of any third parties or their services, including any social networking platforms you choose to use to interact with or to business customers who may retain us to collect and to analyze information provided by their customers.  For information about any third party privacy practices, please consult their privacy policies.

2. Binding Agreement & Consent.
When you visit our Site, you verify that you’ve read and agree to the terms and conditions of this Privacy Policy.

By using the SITES OR Services or allowing someone to use the SITES OR Services on your behalf, you are consenting to our collection, RETENTION, use, disclosure, transfer and storage in accordance with this Privacy Policy of any Personal Data or other information received by us as a result of such use. 

If you do not consent to the terms and conditions set forth in this Privacy Policy, please exit this Site immediately.
3. Changes to Company’s Privacy Policy.
On occasion, it may be necessary for us to update or to make changes to this Privacy Policy.  We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice.

This Privacy Policy was last updated on the date indicated above. Your continued use of the Sites after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.  We will post a notice on the homepage of our Sites if material changes (as determined by us) are made to this Privacy Policy.  When this policy is changed (other than for typographical corrections that do not change its meaning), we will update the “last modified” date at the top of the policy. We also will provide a summary at the bottom of the Policy, describing the types of changes made.

4. Privacy Policy Links.
We think we do a good job at protecting your information and we are committed to transparency in our data security practices.  Accordingly, we make an effort to provide a link to this Privacy Policy in the footer of every page on our Site including those pages on which Personal Data is provided or received, as well as to make it available in all of our software.

5. Access to Information; Contacting Company.
It is vitally important for you to keep your Personal Data accurate, current and complete.  If at any time you need to change or update your Personal Data, please contact us as specified below. We will take immediate steps to update or correct your Personal Data in our possession that you have previously submitted.  Please also feel free to contact us if you have any questions about this Privacy Policy or our information practices.   You can email usinfo@deanmg.com or if you prefer you may write us at 560 W. Washington Blvd, 4th Floor, Chicago, IL 60661 or call us at 312.386.1130.

6. Information We Collect.
Here are a few ways we collect information and the types of information we collect. We may also obtain information from other sources. Information we collect may be in the form of Personal Data or anonymized data. Anonymized data may be in the form of aggregate data. Aggregate data is information we collect about a group or category of services or users from which individual user identities have been removed. In other words, no personal information is included in aggregate data. This Policy does not restrict or limit our collection and use of aggregate data.

Non-Identifiable Data: When you interact with the Sites, we may collect certain personally non-identifiable information (“Non-Personal Data”).  The Non-Personal Data we collect includes without limitation Internet Protocol (IP) addresses, Internet browser type, other characteristics of your device and software, domain names of your Internet Service Provider (ISP), your approximate geographic location, a record of your usage of the Sites, the time of your usage and aggregated data that cannot be used to specifically identify you.

Such information, which is collected passively using various technologies, cannot, in and of itself, be used to specifically identify you.  We also receive certain Non-Personal Data (including, without limitation, of the type set forth above) from various third party sources and services.  We may buy or lease contact data, marketing and demographic data from brokers.  The Non-Personal Data we collect from third parties may be combined with the information we collect as specified herein.

Aggregated Personal Data: In an ongoing effort to better understand and to serve our users, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that has been provided to or received by us. This research may be compiled and analyzed on an aggregate basis and this aggregate information does notidentify you personally and is classified and treated as Non-Personal Data under this Privacy Policy.

Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether emails sent by us or on our behalf are opened and to verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them and to inform our advertisers in aggregate how many users have clicked on their advertisements. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML.

7. Cookies & Other Session Identifiers.
As do most other companies, we utilize a technology called “cookies.” A cookie is a small text file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site.  Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Cookies also help provide additional functionality and help us analyze usage more accurately.  For instance, our Services may set a cookie on your browser that allows you to access the Services during future visits.  The cookie will help the website, or another website, to recognize your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.

Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user’s general information.  These cookies may be used to tailor content (including advertising) you see on the Sites as well as other Internet sites that you may visit in the future.  Cookies may be session cookies (i.e., last only for one browser session) or persistent cookies (i.e., continue in your browser until they are deleted or expire).

Like most websites, we use log files to gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual members, to analyze trends, to administer the site, to track users’ movements on the Sites and the web, to gather demographic information about our user base as a whole.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

In many cases, the information collected using cookies and other tools is used in non-identifiable ways, without any reference to Personal Data.  For example, we use information we collect about Site users (and are provided by clients regarding their Site visitors) to optimize our Site and to understand its traffic and usage patterns.  In other cases, we associate the information we collect using cookies and related technologies with Personal Data.  In that case, this Privacy Policy governs how we use that information.  Additionally, if the settings on your location-aware device allow us to receive geo-location data or information, we may collect that information automatically.

Please note that you have a choice as to whether you want to allow cookies to be utilized; however, if you elect not to allow cookies to be placed as provided herein, you may not be able to use or enjoy all of the features of the Site.  While we recommend that you leave cookies turned on as they allow you to take advantage of some of the features of the Site, you have the ability to control the use and moderation of our cookies.

You can, through your web browser’s option settings, control the use of cookies.  Specifically, you can configure the settings (i) to receive notifications when you are receiving new cookies, (ii) to disable cookies or (iii) to delete cookies.  Please refer to your web browser’s help section for information on how to do this.  In addition to the types of cookies described above, we also use local shared objects, also known as “Flash cookies,” and HTML 5 Local Storage for various purposes, including for fraud prevention and to display content (both on and off the Services) based upon what you view on the Services. Local shared objects and HTML 5 Local Storage are different from cookies described above. Cookie management tools provided by your browser may not remove local shared objects or HTML 5 Local Storage.

The use of cookies by any of our partners, affiliates, or service providers are not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, service providers may use current session ID cookies to help us improve performance and functionality of our Sites.

Advertisers sometimes use their own cookies to provide you with targeted advertising. For example, advertisers may use a profile they have built on sites that you have previously visited to present you with more relevant advertisements. We believe that it is useful to our users to see advertisements that are more relevant to their interests.

If you are based in the United States and would like to learn more, please visithttp://www.aboutads.info/choices/.  If you are based in the European Union and would like to learn more about how advertisers use these types of cookies or to choose not to receive them, please visit www.youronlinechoices.eu.  If you have any queries regarding this Cookie Policy please contact our Privacy Officer by e-mail privacy@deanmg.com.

8. Our Use of Information That We Collect.

8.1 Personal Data
There may be certain circumstances in which we may disclose, transfer or otherwise share your Personal Data with certain third parties without further notice to you, as set forth below.  We use the Personal Data only as specified in this Privacy Policy.  Specifically, we may use the Personal Data in the following ways:

Specific Reason: If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided.  For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or to attempt to resolve your issue and will respond to the email address from which the contact came.

Access and Use: If you provide Personal Data in order to obtain access to or use of the Sites or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to monitor your use of such Services or functionality.

Internal Business Purposes: We may use your Personal Data for internal business purposes including without limitation to help us improve the content and functionality of the Sites, to better understand our users, to protect against, identify or address fraudulent activities, to enforce our Terms of Sites, to manage your account and provide you with customer service and to generally manage the Sites and our business.

Marketing: We may use your Personal Data to contact you in the future for certain marketing and advertising purposes, including without limitation to inform you about services or certain promotional messages which may be of interest to you.  If you wish to change or update your PI or to change your subscription preferences, you may do so by contacting us at any of the addresses provided above.

Business Transfers: As we develop our business, we might sell, buy, transfer or otherwise acquire or dispose of certain businesses or corporate assets.  In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data (as defined herein) may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of the Company (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.  We will ensure that any successor or acquirer of the Company will treat your Personal Data as securely and confidentially as VRB.

Subsidiaries and Affiliates: We may also share your Personal Data with our subsidiaries and/or affiliates consistent with this Privacy Policy.  Our subsidiaries and affiliates will be bound to maintain any Personal Data in accordance with this Privacy Policy.

Agents, Consultants and Related Third Parties: We, like many businesses, sometimes engage other companies to perform certain business-related functions on our behalf so that we can focus on our core business.  Examples of such functions include mailing information, maintaining databases and processing payments.  When we engage another company to perform these (or other) functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.  We will retain only those third-party service providers adhere to the same or similar privacy standards that we do.

Legal Requirements: We may disclose your Personal Data if required to do so by law (including, without limitation responding to a subpoena or request from law enforcement, court or government agency) or in the good faith belief that such action is necessary (i) to comply with a legal obligation, (ii) to protect or defend our rights, interests or property or that of other customers or users, (iii) to act in urgent circumstances to protect the personal safety of users of the Services or the public or (iv) to protect against legal liability as determined in our sole and unfettered discretion.

If we intend to use any Personal Data in any manner that is not specified herein, we will inform you of such anticipated use prior to or at the time at which the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.  In short, we will honor the choices you’ve made regarding your Personal Data and will inform you about any other intended uses of such information.

8.2  Non-Personal Data
Non-Personal Data does not and cannot be used to personally identify you.  Accordingly, we may use such information for any lawful purpose.

8.3  What We Do Not Do With Your Information
Dean Media Group will not disclose any Personal Information about you unless specifically agreed to you by you or to (1) comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as a financial threat to you or others. In the event that we are legally compelled to disclose your Personal Information to a third party, we will notify you unless doing so would violate the law or court order.

8.4 Your Information Choices and Changes
You may opt-out of receiving promotional emails from us by following the instructions provided in those emails. If you choose to unsubscribe, we may still send you non-promotional communications, such as emails about your accounts, product notices, user forum notices or our ongoing business relations.

We will retain your information collected for a commercially reasonable period of time for us to provide services to you and to use it as stated in this Privacy Policy.  In addition, we will retain your information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. Removing or rejecting cookies could affect certain features or services of our Sites.

You may send an email (privacy@deanmg.com) to:

• request changes to your contact preferences,

• request access and changes to your personal information. If you would like this information edited or deleted, we will respond to your request within 30 days,

• opt-out of our sharing your information with independent third parties. 

9. Information We Collect On Behalf of Our Customers
Dean Media Group acts as a service provider for each of our customers, in that we provide our services for the benefit of the customer.  Each of our customers uses certain of our products and services to gather information about their own customers and visitors to their sites and digital properties (collectively, “Customer Data”). Each customer instructs us as to what types of Customer Data it would like us to collect on its behalf.

We treat Customer Data as the property and confidential information of the applicable Dean Media Group customer. We reserve a limited right to disclose any collected data as required by law, a valid court order or other request from a governmental authority. Other than under such a limited right, we do not share information collected for one customer with our other customers or with any third party.

We follow our customers’ instructions on cookie placement. To control the placement of cookies set while visiting our customers’ web sites, please consult their privacy statement and cookie settings.

10. Children.
Protecting the privacy of children is extremely important to us.  We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data without parental consent.  If you have reason to believe that a child under the age of 13 has provided Personal Data to us, please contact us, and we will endeavor to delete that information from our databases as soon as possible.

11. Links to Other Web Sites.
This Privacy Policy applies only as specified herein. The Site may contain links to other websites not operated or controlled by us (the “Third Party Sites”).  The policies and procedures set forth herein do not apply to any Third Party Site.  The owners and operators of all Third Party Sites are responsible for Personal Data and Non-personal Data provided, collected, maintained, store or otherwise disclosed on those sites.  The links from the Services do not imply that we endorse or have reviewed the Third Party Sites, including their privacy policies, if any.  We strongly encourage contacting those sites directly for information on their privacy policies.

12. Storage and Security.
The security of your personal information is a top priority for us. Experts design our security measures and we use a variety of technologies and procedures to help protect the security of your personal information from unauthorized access, use and disclosure.  We restrict access to personal information to Dean Media Group employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

13.  Phishing.
We do not and will not, at any time, request your Personal Data or other personal information in a non-secure or unsolicited email or telephone communication.  Identity theft and the practice currently known as “phishing” are of great concern to us.  Safeguarding information to help protect you from identity theft is one of our priorities.  For more information about phishing, visit the Federal Trade Commission athttp://222.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.pdf.

14. International Privacy Laws.
If you are visiting our website from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located.  We will hold and process your Personal Data and Non-Personal Data in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in other countries.

15. Information Regarding Your Information.
You can request a copy of the Personal Data that we hold about you.  If you would like a copy of some or all of your Personal Data, please contact us via the addresses specified herein.  We want to make sure that your information is accurate and current.  You should ask us to correct or remove information which you think is inaccurate or outdated.