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TMT DIGITAL, INC. d/b/a The Media Trust (“TMT”) respects the privacy of all visitors to its public website, www.mediatrust.com (“Website”). This Privacy Statement (“Statement”) explains how TMT collects, uses, stores and protects the information that we collect from our Website, as well as your rights and choices regarding the information that we collect.
TMT is a U.S.-based company with domestic and international business clients. As a result, information that we collect on our Website, including personal information, may be transferred to our U.S. offices to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, personal information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the information was initially collected. In all such instances, we use, transfer, and disclose personal information solely for the purposes described in this Statement.
If you have any questions or concerns about this Statement or about TMT’s privacy and data security practices, please contact us at info@themediatrust.com.
This Statement does not apply to data that TMT collects on its secure, client-specific services platform www.themediatrust.com (“Client Website”), which we use to provide services to our clients. When you access the Client Website, you are doing so in a business capacity as a representative of your company, and your interactions with the Client Website are governed by our relationship agreement with your company. See “TMT Product Services Privacy Policy” below.
This Statement also does not apply to personal information that we collect and use for employment-related purposes, whether through this website or through a website operated on our behalf by a third-party service provider.
For purposes of this Statement, “Personal Information” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source. Personal Information stops being personal information when it has been aggregated, deidentified, or otherwise anonymized sufficiently that the individual is no longer identified or identifiable using reasonable efforts, resources, and technology.
Categories of personal information that we collect on the website:
If you choose to communicate with us through an online form, send us an email, or otherwise contact us, we will collect whatever information, including personal information, that you choose to provide us with.
Information that We Collect Automatically When You Visit Our Website
TMT does not collect personal information from or about you from third parties, or combine information from other sources with the information described in this Statement.
TMT does not collect, use, share, or disclose your personal information for anything other than the following lawful purposes:
To the greatest extent possible, we will use aggregated, deidentified, or otherwise anonymized data to accomplish these purposes, but if we do not, or if we combine it with Personal Information we will continue to treat personal information in accordance with this Privacy Statement.
Except to the extent necessary to fulfill our business obligations, to accomplish one of the lawful purposes described in this Privacy Statement, or pursuant to your express instructions, we do not sell, transfer, or otherwise disclose personal information that we collect from or about you.
With your express consent: In the course of delivering contracted services, we will share your personal information with companies, organizations, or individuals outside of TMT when we have your prior express consent to do so.
When You Choose to Directly Share Your Information About Our Website or Your Usage of It: When you use our Website, certain features allow you to make some of your usage and content accessible to the public, directly or through social media platforms. We urge you to consider the sensitivity of any information prior to sharing it publicly or with other users.
When Necessary to Comply with Laws and Law Enforcement Requests or Otherwise to Protect TMT, Its Clients, and Individuals We may disclose your information (including your personal information) to a third party if:
We may share or transfer your information (including your personal information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will take reasonable steps to assure that any other entity involved continues to comply with the terms of this Privacy Statement. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
We may share personal information that has been aggregated, deidentified, or otherwise anonymized and thus does not directly or indirectly identify you and that cannot, with reasonable efforts, resources, and technologies, be used to reidentify you. Such aggregated, anonymized, deidentified, or otherwise not re-identifiable information is not personal information within the scope of this Privacy Statement or applicable privacy laws.
TMT uses reasonable organizational, technical, and administrative measures to provide a level of security appropriate to the risk associated with the personal information that we collect. We protect personal information under our control against — and require our service providers to also protect against – accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, personal data that is transmitted, stored, or otherwise processed. Only authorized employees have access to the data you provide, and that access is limited to least privilege, need to know access. All TMT employees who have access to the data you provide have agreed to maintain the confidentiality of that information. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have concerns about the security of your information with TMT, please contact us immediately at info@themediatrust.com.
TMT retains information only as long as necessary to accomplish the business purpose for which it was collected and to comply with its legal and contractual obligations, plus 1 year, and then securely disposes of that information or convert it into non-personal information by aggregating it, de-identifying it, or otherwise anonymizing it so that it does not directly or indirectly identify you and cannot, with reasonable efforts, resources, and technologies, be used to reidentify you..
Our Website, and the services we provide to our clients, are not directed to or intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under the age of 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child under the age of 16 has provided us with personal information, please contact us at info@themediatrust.com.
California Civil Code Section 1798.83 permits Website users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at info@themediatrust.com.
This policy applies to the processing by TMT Digital, Inc dba The Media Trust (“TMT”)of personal information in connection with the provision of our digital advertising and website security services (“TMT Services”) to our business customers (“Clients”) relating to end-users (“you”) which we may collect via our client-specific services platform at www.themediatrust.com, (“Client Website”) and/or our Client’s own digital properties and/or content. Our use of this information is restricted by our agreements with our Clients. This policy is meant to articulate how we enable and safeguard privacy in connection with such processing.
This policy applies to the personal information collected from you or inferred about you through your use of TMT Client Website and your interactions with our Client’s own digital properties and/or content.
Our Client Website is intended for use by Clients, and is operated by us on behalf of our Clients. Where you are accessing the Client Website in your capacity as a worker of one of our Clients, your use of the Client Website maybe subject to that Client’s policies, if any.
This policy applies to the limited personal information we may collect and use for our own purposes as a data controller in connection with user authentication into Client Website and user experience (UX) research, and it covers personal information we process on behalf of our Clients as a data processor through their use TMT Services received by your Organization from TMT’s Operations Team. It’s primarily our Clients, as the data controller, that control what personal information about you that we collect and how we use it.
If you have privacy related questions or concerns about a Client’s privacy practices or the choices that Client has made to share your information with us or any other third party, you should refer to that Client’s privacy policies, and reach out to the individual(s) who manage the TMT vendor relationship at that Client.
TMT would not be responsible for the privacy or security requirements of our Clients outside of the services we provide; which may differ from those set forth in this policy.
If you have any questions about this policy, please reach out to the TMT team using the “Contact Us” section of this policy.
At TMT we take the security of personal information very seriously. In line with industry best practice, we collect personal information directly from you in connection with your use of the Client Website. We also collect personal information from you if you visit or interact with our Client’s digital properties and/or content, and that information is used to facilitate the delivery of the TMT Services to our Clients, including monitoring the assets, providing support, and for TMT’s own analytics and product improvement purposes (“Usage Data”) as mentioned in Table 1.1 below.
Table 1.1
Our third party providers (also known as ‘subprocessors’) only receive personal information about you for the limited purposes of providing us with their services. Examples of those third parties include, but are not limited to:
Our subprocessor list can be requested at info@themediatrust.com.
Personal information may be collected via cookies and tracking technologies embedded within TMT Services. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We use tracking cookies, such as Google Analytics and Hotjar, to record the Services’ user activity and report on what pages and features users utilize.
If you’d like additional information regarding cookies, or if you decide at any time that you no longer wish to accept cookies, other than those necessarily required for the function and operation of Services and the delivery of our Services, please contact us at info@themediatrust.com or submitting a form via our website Contact Us.
Do not track browser settings:
Some Internet browsers like Firefox, Internet Explorer, and Safari include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, we do not currently process or respond to “DNT” signals. To learn more about “DNT”, please visit “All About Do Not Track“.
Our subprocessor list can be requested at info@themediatrust.com.
Where we collect your personal data, in our capacity as our Client’s processor, it is our Client’s responsibility to ensure we have a lawful basis to do so. However typically our Client’s will rely on the fact it is in their legitimate interest to use our services for the following purposes:
Where we collect your data in our capacity as a controller (i.e., for user authentication and UX research), we rely on our legitimate interest of ensuring the safety of the Client Website and to provide the best possible experience to Clients and users.
We use industry best practices that are the most appropriate administrative, organizational, technical and physical measures designed to protect the personal information that our customers provide to us. For example, TMT employs at various points in our infrastructure logical and physical access controls, encryption, firewalls, intrusion detection and network monitoring, and secure development practices.
Only authorized personnel have access to the personal information you provide, and each TMT employee with access to personal information is obligated to maintain its integrity and confidentiality.
If you have reason to believe that your interaction with us is no longer secure, you should immediately Contact us at info@themediatrust.com.
TMT respects you and your privacy and data protection rights. Depending on where you live, the kinds of personal information we’ve collected about you, and the nature of how we process it, you’ll be able to exercise certain rights over your personal information based on regulations and laws that apply.
Residents of the European Economic Area (EEA), the United Kingdom, and Switzerland:
Under applicable data protection and privacy laws in the EEA and UK, you have the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority.
If you would like to exercise any of your rights, please submit a privacy request via the contact us link on our web site www.mediatrust.com. Or you may contact us via telephone at +1 703.893.0325 or via email to info@themediatrust.com
Please note TMT responds to only verifiable privacy requests received from individuals who wish to exercise their privacy and data protection rights in accordance with the European Union General Data Protection Regulation (EU GDPR).
We prefer to answer your questions, requests, and concerns about how we handle personal information directly. We will make good faith efforts to honor reasonable requests submitted to us. You do have the right to lodge a complaint with EU Data Protection Authorities (DPAs) about TMT’s collection and use of your personal information. For the contact information of the Data Protection Authorities for each European Union Member State, please click here.
EU IAB TCF Certification
TMT participates and complies with the rules of an advertising industry framework called the IAB Europe Transparency & Consent Framework (“IAB TCF”), which consists of a set of technical specifications and policies to which members must adhere. IAB TCF is designed to ensure that end users are provided with a choice as to the purposes for which their personal data is processed and the companies that are permitted to process their data.
TMT’s IAB TCF identification number is 1044
California residents rights under the California Consumer Privacy Act (‘CCPA’)
TMT operates as a Business to Business (‘B2B’) cyber security operations company, and the CCPA provides consumers (California residents) with specific rights regarding the processing of their personal info. TMT only responds to verifiable requests received from individuals who wish to exercise their privacy and data protection rights in accordance with applicable data protection laws. When contacting us, please provide us with detailed information about the personal information requesting we correct, update, amend, or remove, and the timeframe and manner in which we came to collect your personal info.
We will not sell, trade, or rent personal information of a California resident. Specific to the personal information we are responsible for as a data processor in our Services, if you would no longer like to be contacted by one of our customers or would like to have your personal information corrected, updated, amended, or removed, please contact our TMT customer (“the data controller”) directly. Requests submitted via our contact us link, which pertain to personal information we hold as a data processor, will be deferred to your Organization.
TMT will not discriminate against you or our customers (e.g., through denying Services, or providing a different level or quality) for exercising any of the privacy and data protection rights afforded to you.
Subject to exceptions, we can receive requests for disclosure or deletion of personal information that we handle as a Data Controller. Requests may be submitted via the contact us link on our web site.
If TMT obtained your personal information via a third party acting on your behalf, you should contact the company/entity or person you provided your information to.
We keep your personal information only for as long as it is warranted to provide our Services, fulfill our commitments to your Organization, and/or adhere to legal or regulatory requirements. Certain personal information may be kept and archived beyond our relationship or the end of our Services, as required for legitimate interests such as recordkeeping, backing up Services data, statistical insights/metrics for product enhancement purposes, for example. Notwithstanding outside legal, regulatory, or contractual restrictions, TMT will retain the following Services and Services data based on the schedule outlined below:
TMT adopts a data minimization approach when it comes to personal information that we retain beyond one (1) year. When personal information is deemed expired, no longer needed, and does not have to be retained, we follow industry best practices with the secure deletion, destruction, and anonymization of personal data, depending on what method is systematically and procedurally possible, most secure, and what our related retention commitments are. As retention periods lapse, we use automated processes through periodic audits to identify and securely delete personal info. If automated deletion is not possible, secure manual deletion may be performed.
Personal information may be transferred, stored, and processed by us or our third party vendors in countries whose data protection laws and regulations may be different to those of your country.
TMT only permits cross border (‘international’) transfers of personal information made between countries or regions when supported by an appropriate legal agreement or an alternative provision that ensures sufficient safeguards and obligations to personal information rights are commensurate. The sufficiency of these agreements and provisions depend on the countries or regions the personal information is transferred from and to. Examples of agreements and provisions that may be suitable for transfers (depending on the nature of the international exchange) include, but are not limited to, the following:
We do not knowingly collect information relating to children. If we learn that we have collected personal information from an individual deemed to be under the age of 16, we will take appropriate measures to investigate and address the issue promptly. The use of our Services are specifically for delivering cyber security operations solutions to businesses and not children.
We are constantly looking to improve our site and services, so we may need to update this privacy policy from time to time. We will notify you of any substantive changes to our policy.
We will do this for our Privacy Policy by, for example, placing a notice on our site/and or by sending you an email (if you have registered your email details with us) when we are required to do so by applicable law. You will be able to see when this Privacy Policy was last updated by checking the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes. Any change or update to our privacy statement will be posted on our website under “Privacy Statement” at least 30 days prior to implementation.
If you have questions, complaints, or concerns about this Privacy Statement, your personal information, or our use and disclosure practices, or you wish to exercise your options as described in this Privacy Statement, please contact us at info@themediatrust.com.
If you have any questions or requests about this privacy policy, our Services, or how we manage your personal info, please contact us through our contact us link on our web site or by contacting:
TMT Digital, Inc.
Attn: Security and Privacy Team
PO Box 8056
McLean, VA 22106
Email: info@themediatrust.com
YOUR Data. We take privacy seriously. If you’d like to know the data we have about you, all you have to do is ask. You can contact us via email at info@themediatrust.com
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