UPDATED: July 2018
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 firstname.lastname@example.org.
Information Collection Not Covered by this Statement
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.
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.
What TMT Means by “Personal Information”
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.
Information that We Collect From and About You
Categories of Personal Information that We Collect on the Website
- Email addresses
- Telephone numbers
- Business contact information, including names, email addresses, business addresses, telephone numbers, company name or business affiliation, and title.
- User IDs and passwords
- Personal information that you choose to share with us voluntarily when you ask a question, request follow-up, or otherwise interact with us
- Identifiers of devices used to access the Website
- Locations of devices used to access the Website
Information that You Provide to Us Voluntarily:
If you choose to communicate with us through an online form, sending 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
Our Website automatically creates logs regarding user sessions that contain information about the features that you use, the actions that you take, and the information that you access. When your session ends, TMT only retains the information in a statistical and aggregated format (non-personal information) that we use for research purposes, assessing the effectiveness of our Website, and improving user experience.
Cookies are small pieces of information transferred to your computer's hard drive through your web browser to enable our systems to recognize your preferences and settings. Cookies collect information such as the type of search engine used, the sections of the website visited, and other website usage information. Most browsers automatically accept cookies, and you may manually disable them. For more information on disabling cookies, go to the "help" menu on your browser. The Website may still be viewed if you choose to disable cookies, but your use and enjoyment of the website may be adversely affected.
We use session cookies for website use and function, and those cookies expire at the end of the session. We use persistent cookies, but only to identify existing TMT clients when they visit our Client Website. TMT may retain information from the session and persistent cookies in a statistical and aggregated format (non-personal information) for research purposes, assessing the effectiveness of our Website, and improving user experience.
We use Matomo Analytics to collect and assess information about user activities on our website to improve our Website and user experience. That information includes device/operating system, geography, page visited, length of page view, referring page, exit page and more. [We limit the information we collect and use from Matomo Analytics by customizing our implementation to not track traditional personal-identifying information. We collect and retain information from Matomo Analytics in a statistical and aggregated format (non-personal information) for research purposes, assessing the effectiveness of our Website, and improving user experience. For more information about Matomo Analytics and your options with regard to the data it collects, see Matomo Analytics.
Information that We Collect From Other Sources
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.
Why We Collect Information From and About You
TMT does not collect, use, share, or disclose your personal information for anything other than the following lawful purposes:
To establish and maintain contractual relationships with our clients
- To establish relationships with new clients To fulfill our obligations to current clients
- To contact clients regarding account-related issues and business communications, including technical notices, updates, security alerts, and administrative messages
- To enable individuals to access and use our Services
To comply with our legal obligations:
- To demonstrate compliance with applicable privacy and data security law
- To comply with incident monitoring, reporting, assessment, and notification requirements
- To comply with other applicable criminal and civil law and regulatory requirements under federal, state, and international law
To provide services and information that you request to receive:
- To provide customer service and support
- To communicate with you, including responding to your comments, questions, and requests
- To process and complete transactions, and send you related information, including purchase confirmations and invoices
- To provide direct marketing, email, and other distributed information distribution
To fulfill our other legitimate interests to the extent that they are not overridden by individual interests, fundamental rights, or freedoms:
- To administer, operate, maintain, and secure our website and Services
- To monitor and analyze trends, usage, and activities in connection with our Services
- To investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities
- To verify compliance with our internal policies and procedures For accounting, recordkeeping, backup, and administrative purposes
- To customize and improve the content of our communications, websites, and social media accounts
- To provide information and education
- To provide, operate, maintain, improve, personalize, and promote our business
- To develop new products, services, features, and functionality
- To market our products and services (first-party marketing only; we do not provide personal information to third parties for use in marketing any non-TMT goods or services)
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.
TMT Information Sharing and Disclosure
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 believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request;
- To enforce our agreements, policies and terms of service;
- To protect the security or integrity of TMT’s products and services; To respond to an incident involving personal data for which TMT has direct or indirect responsibility
- To protect the property, rights, and safety of TMT, our clients, or the public To prevent harm or illegal activities
- To respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or
- To investigate and defend ourselves against any third-party claims or allegations.
As the Result of a Business Transition:
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.
Sharing Aggregate, Anonymized, Deidentified, or Otherwise Non-Personal Data:
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.
Your Control Over Information that We Collect from and About You
- You may decline to share certain personal information with us, in which case we may not be able to provide you with some of the features and functionality of our Website or fulfill your requests.
- You may decline to accept cookies, but that decision may affect the functionality and performance of our Website.
- You may update or correct your personal information at any time by accessing the account settings page on the Website.
- You may opt out of receiving TMT promotional communications by using the unsubscribe link within each email. Note that, as long as you maintain an account with us, you will continue to receive administrative messages from us regarding the Services.
- You may request information about, and access to, the personal data that we collect from you.
- You may ask questions or make complaints about our privacy and data security practices with regard to your personal data.
- You may request that we delete information that we have collected about you.
- You may ask us for a copy of the information that we collected from you. To exercise any of these options or for additional information about our privacy and data security practices, contact us at email@example.com.
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 firstname.lastname@example.org.
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 email@example.com.
California Privacy Rights
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 firstname.lastname@example.org.
Changes to this Privacy Statement
TMT may change and update this Privacy Statement from time to time, including materially changing the use made of personal information described herein. Any change or update to our privacy statement will be posted on our website under "Privacy Statement" at least 30 days prior to implementation.
Questions, Complaints, and Additional Information
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 email@example.com.