The Marketing Arm Inc. (“TMA”) and its operating subsidiaries Alcone Marketing Group, Inc., Fanscape LLC, and Platinum Rye, LLC respect the privacy of every person who visits TheMarketingArm.com (“the Site”) and who uses the services that we make available from the Site (our “Services”) and we are committed to ensuring a safe online experience.

1. PURPOSE OF THIS POLICY

This privacy policy (“Privacy Policy”) explains our approach to any personal data that we might collect from your or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Policy also sets out your rights in respect of our processing of your personal data. For more information, click here.

This Policy does not cover data rendered anonymous or where pseudonyms are used. Data is rendered anonymous if individuals are no longer identifiable or are only identifiable with a disproportionately large expense in time, cost, or labor. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult.

2. WHO WE ARE AND WHAT WE DO

The Marketing Arm site is operated by The Marketing Arm Inc., and is edited and maintained by a vendor. We are a marketing agency that provides activations on behalf of our clients. These activations could be in the form of digital, experiential, social, and print mediums and channels; collectively known as our Services. Our Services are operated by us internally and/or our vendors and partners.

3. HOW TO CONTACT US

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact our Data Protection Officer (“DPO”) by:

  • Sending a letter to:
    The Marketing Arm Inc.
    Attention: Data Protection Officer
    1999 Bryan Street, Suite 3200
    Dallas, TX, USA 75201
  • Sending an e-mail to TMA_Privacy@themarketingarm.com
    Attention: Data Protection Officer; or
  • Calling us at: (214) 259-3200

4. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

Through the TMA Site, we may obtain the following types of personal data when you choose to provide it:

  • Information such as cookies, your IP address, and web analytics.

On behalf of our clients, TMA may collect information such as the following:

  • Your name, email address, and postal address.
  • Personal Data Consumers may provide on TMA’s website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
  • In addition, TMA may obtain Personal Data, such as contact information and financial account information, of its client’s and vendor’s representatives. TMA uses this information to manage its relationships with its clients and vendors, process payments, expenses and reimbursements, and carry out TMA’s obligations under its contracts with our clients and vendors.

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process; or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property, or safety of us or third parties, including our clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

I. FULFILMENT OF PRODUCTS AND SERVICES.

We may collect and maintain personal data that you voluntarily submit to us or our clients and vendors during use of the Site and/or use of Services. We use the contact and payment details you have provided so that we may fulfil the supply of products and services you have ordered. This includes your purchase of products or your attendance at events hosted by us or our third-party partners.

A. WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THIS PURPOSE?

We may share your personal data with the following categories of third-parties:

  • To verify card payments and process refunds or disbursement of prizes: credit card companies, other payment providers, and applicable governmental authorities;
  • To deliver products and process returns: delivery and courier companies; and
  • Events: any applicable third-party hosting the event and ticketing companies; and
  • Websites: any applicable third-party site engaged in sweepstakes, promotions, and product engagement.

B. WHAT IS OUR LEGAL BASIS?

It is necessary for us to use your personal data to perform our obligations in accordance with your consent and any contract that we may have with you.

II. CUSTOMER INSIGHT AND ANALYSIS.

We analyze your contact details with other personal data that we observe about you from your interactions with our Site or our email communications to you regarding the products, and services or other capabilities provided by TMA.

Where you have given your consent (where lawfully required), we use cookies, log files, and other technologies to collect personal data from the computer and software you use to access the Site, or from your mobile device. This includes the following:

  • An IP address to monitor Site traffic and volume;
  • A session ID to track usage statistics on our Site; and
  • Information regarding your personal and professional interests, demographics, buying habits, experiences with our products, and contact preferences.

Our Site and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail, and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We share your personal data with third-party service providers who assist us with customer insight analytics. These providers include those described in Section 6 of this Policy, Our Use of Cookies and Similar Technologies.
    Some of our third-party providers are located in the USA and their use of your personal information is governed by regulations such as the US Privacy Shield and, in some cases, the General Protection Data Regulation.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymized personal data may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, we may process your personal data for certain legitimate business interests to use your personal data in such a way to ensure that we provide the very best products and services for the benefit of you and our other customers.
    We will only use your location data for customer insight purposes where we have your consent to do so.

III. MARKETING COMMUNICATIONS.

We carry out the following marketing activities using your personal information:

A. POSTAL MARKETING.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or communications we receive from your interactions with our clients and vendors (see the Customer Insight and Analysis Section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We share your personal data with third-party postal providers, such as FedEx and the United States Postal Service who assist us in delivering our postal marketing campaigns to you, including the post office.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymized information may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, such as your postal address, we may process your personal data for certain legitimate business interests in order to use your personal information for postal marketing that is of interest to you.
    We will only use your location data where we have your consent to do so.

B. EMAIL MARKETING.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or communications we receive from your interactions with our clients and vendors (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We share your personal data with third-party email marketing providers who assist us in delivering our email marketing campaigns to you.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, we will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

C. ONLINE PERSONALISED ADVERTISING.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or communications we receive from your interactions with our clients and vendors (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised online advertising.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We share your personal data with third-party service providers who assist us with our online personalised advertising campaigns such as Email Service Providers (“ESP”) and fulfilment centers. These providers are described in Section 6, Our Use of Cookies and Similar Technologies.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the personal data will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details. Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, we may process your personal data for certain legitimate business interests in order to use your personal information for direct marketing purposes.

D. SOCIAL MEDIA RE-MARKETING.

We use information that we observe about you from your interactions with our Sites, our email communications to you and/or communications we receive from your interactions with our clients and vendors (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised advertising on social media channels operated by Facebook, Google, Instagram, LinkedIn, and/or Twitter where you are a registered user of such services.

We do this using Facebook Customer Audiences, Google Customer Match, Instagram, LinkedIn, and/or Twitter espectively.

Please note that such activity is also subject to the privacy choices you have elected to make on such services.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We may share your personal data with third-party service providers who assist us with social media remarketing campaigns.
    Your email address is also shared by us or our third-party service providers with the third-party social media service providers listed in Section III (D) (Facebook and/or Google) under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the personal data will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, we may process your personal data for certain legitimate business interests in order to use your personal data for direct marketing purposes.
    We will only engage in social media remarketing where you have consented to us using your email address and/or sharing your email address with the third-party social media service providers listed in Section III (D) for marketing purposes.

E. SOCIAL MEDIA INSIGHT.

Where you are a registered user of a social media platform service, such as Facebook or Google, we may use your email address to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

  • Information that we observe about you from your interactions with our Sites, our email communications to you and/or communications we receive from your interactions with our clients and vendors (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
  • The information the social media platform holds about you.

We do this using Lookalike Audiences and/or Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH FOR THESE PURPOSES?
    We may share your personal data with third-party service providers who assist us with social media remarketing campaigns.
    Your encrypted data is also shared by us or our third-party marketing consultancies with the social media platform under the terms of their Customer Audience Policies.
  • WHAT IS OUR LEGAL BASIS?
    Where your personal data is completely anonymized, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymized personal data may be subject to other laws where your consent is required. Please see Section 6, Our Use of Cookies and Similar Technologies, for further details.
    Where your personal data is not in an anonymous form, we will process your personal data for certain legitimate business purposes which include using your personal data for marketing purposes.

5. HOW WE OBTAIN CONSENT

Where our use of your personal data requires your consent, you can provide such consent:

  • At the time we collect your personal information following the instructions provided; or
  • By informing us via US Mail, e-mail, or phone using the following contact details:

6. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

In order to provide you with a more personalized and responsive experience, our TMA Site uses small text files, called cookies. Generally, cookies are used to retain small amounts of information and are downloaded to your computer or other device by a server for our Site. Your web browser then sends these cookies back to this TMA Site each time you visit, so we can recognize you and remember your user preferences.

Our TMA Site also uses analysis and tracing services to track the performance of our services, understand how you use our services, and offer you a safer and improved experience. Information about your usage of our Site may be collected and processed by TMA, or a third party engaged by TMA. Without the knowledge we gain from using these cookies, we would not be able to provide the level of services we do.

Consent to tracking and analysis
By using our TMA Site, you consent that TMA may use cookies and third-party services, and collect your usage data under a unique identifier, for the purposes of tracking, analysis, and improvement of our Site.

You may, at any time, withdraw your consent by disabling cookies on TMA’s website. The most effective way to do this is to disable cookies in your browser. Each web browser offers a way to manage and delete cookies. We suggest consulting the help section of your browser to change your cookie preferences.

For the purposes of tracking the performance of our services and to improve TMA services, TMA uses the following third-party services:

Google Analytics
Our TMA Site also uses Google Analytics, a third-party analytic service, to track the performance of our services, understand how you use our services, and offer you and improved and safer experience. Google Analytics uses cookies stored on your computer to allow for analysis of your visits to our website and interactions with it in order to personalize your experience and improve our services.

Google analyzes this information to offer TMA reports on website usage and online usage of associated services. Google may also transfer this information to third-parties either when required to do so by law or when third-parties are contracted by Google to process the data. Google undertakes not to associate your IP address with any other data held by Google.

You can prevent cookies from being stored on your computer by changing your browser settings. However, if you choose to do so, your user experience on our Site may be altered. By using TMA’s Site, you consent to have non-personal data used and processed by Google as described above. You can withdraw consent for this use of your data at any time.

Adobe
If you have Adobe Flash installed on your computer and you use some of this website’s audio or video players, Google Analytics may try to store additional cookies on your computer. This type of cookie is known as a Local Shared Object or Flash cookie. This cookie helps analyze the popularity of media files.  This cookie can count the total number of times each file is played. Adobe’s website offers tools to control Flash cookies on your computer. These cookies can be controlled manually by visiting the Adobe website.
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

7. THIRD PARTY LINKS AND SERVICES

Our Site contains a link to a third-party website, Greenhouse Software, Inc. Please remember that when you use a link to go from our Site to another website, or you request a service from a third-party, this Privacy Policy no longer applies. For more information, click here.

8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Subject to applicable law, TMA retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves the purpose for which the Personal Data was originally collected or subsequently authorized by the Consumer.
If your information is only useful for a short period, e.g. for specific marketing campaigns, we may delete it.

9. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to keeping the personal data you provide to us secure. We will take reasonable precautions to protect your personal data from loss, misuse, or alteration. For more information, click here.

10. HOW TO ACCESS YOUR INFORMATION AND OTHER RIGHTS

European Union residents have the following rights in relation to the personal information we hold about you:

  • Your right of access. For more information, click here.
  • Your right to rectification. For more information, click here.
  • Your right to erasure. For more information, click here.
  • Your right to restrict processing. For more information, click here.
  • Your right to data portability. For more information, click here.
  • Your right to object.
    You can ask us to stop processing your personal data, and we will do so, if we are:
    • Relying on our own or someone else’s legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
    • Processing your personal data for direct marketing.
  • Your rights in relation to automated decision-making and profiling. For more information, click here.
  • Your right to withdraw consent. For more information, click here.
  • Your right to lodge a complaint with the supervisory authority. For more information, click here.

if you wish to enforce any of these rights, please contact our data protection officer by:

  • Sending a letter to:
  • The Marketing Arm Inc.
    Attention: Data Protection Officer
    1999 Bryan Street, Suite 3200
    Dallas, TX, USA 75201
  • Sending an e-mail to TMA_Privacy@themarketingarm.com
    Attention: Data Protection Officer; or
  • Calling us at: (214) 259-3200

11. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA

We may transfer personal data we collect about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described herein. Your personal data may also be transferred by us to our other offices and/or to third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (“EEA”).

For purposes of this Policy, the EEA includes Iceland, Liechtenstein, Norway, and those countries in the European Union.

If you are located in the EEA, we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA. With respect to transfer of personal data to the U.S., TMA, is certified under the EU-U.S. Privacy Shield framework developed by the U.S. Department of Commerce and the European Commission regarding the transfer of personal data from the EEA to the U.S.

12. YOUNG USERS

TMA does not knowingly collect or use personal data from children under the age of thirteen (13). If TMA gains actual knowledge that information has been collected from children under the age of thirteen in the United States in contradiction with the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, TMA will not disclose the data and reserves the right to immediately delete the user profile and related information from our servers.

If you are located in the EEA, you are only permitted to use our services if you are over the relevant age, at which you can provide explicit consent to the processing of your data under the laws of your country, or if you have the consent of your parent or legal guardian. If you are a parent and learn that your child is using TMA’s website without permission or if you have any specific questions about data privacy at TMA, please do not hesitate to contact us at TMA_Privacy@themarketingarm.com.

13. ACCESS AND CORRECTION

TMA does not assume responsibility for confirming the ongoing accuracy of your Personal Data. When practically possible if you inform TMA that your Personal Data is no longer accurate, appropriate corrections will be made.

14. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. If there are changes or additions to this Privacy Policy, we will notify you by posting those changes here. Changes and additions to this Privacy Policy are effective when they are posted. Please check this web page periodically to see any changes we have made to our Privacy Policy. Date of last Revision to Privacy Policy: May 25, 2018. For more information, click here.

15. LEGAL DISCLOSURES

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of users of the TMA Site. We attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements The Marketing Arm Inc. Privacy Policy and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect the following categories of personal information about you:

  • identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.
  • additional data subject to cal. civ. code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
  • protected classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status.
  • commercial information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • online activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • geolocation data
  • sensory information: audio, electronic, visual, and similar information
  • employment information: professional or employment-related information
  • education information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Debugging to identify and repair errors that impair existing intended functionality [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Undertaking internal research for technological development and demonstration [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.

2. OUR PRIOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

We may have collected and used your personal information, as described in Section 1 above, during the twelve (12)-month period prior to the effective date of this Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have discussed for a business purpose.

  • sources of personal information
    We may have obtained personal information about you from various sources, as described below.
Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you contact us with a [question or comment] [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
From your devices, such as when you visit our Site [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Our affiliates and subsidiaries [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Vendors who provide services on our behalf [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Social networks [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Government entities [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
  • sharing of personal information
    We may have shared your personal information with certain categories of third parties, as described below.
Categories of Third Parties Categories of Personal Information
Our affiliates and subsidiaries [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Vendors who provide services on our behalf [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Professional services organizations, such as auditors and law firms [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Our business partners [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Internet service providers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Data analytics providers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Government entities [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Operating systems and platforms [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Social networks [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
  • sale of personal information
    We do not sell your personal information in exchange for monetary compensation.
    We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
  • disclosure of personal information for a business purpose
    We may have disclosed to third parties the following categories of personal information for a business purpose:
    • Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
    • Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
    • Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
    • Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
    • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
    • Geolocation Data
    • Audio, electronic, visual, and similar information
    • Professional or employment-related information
    • Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
    • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

3. CALIFORNIA CONSUMER PRIVACY RIGHTS

You have certain choices regarding our use and disclosure of your personal information, as described below:

  • access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • deletion: You have the right to request that we delete certain personal information we have collected from you.
  • how to submit a request: To submit an access or deletion request or to submit a Shine the Light request, please email us at TMA_Privacy@themarketingarm.com or call us at 1(833) 520-0506.
  • verifying requests: To help your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request if you request access to or deletion of your personal information, we may require you to provide us with additional about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
  • additional information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact TMA_Privacy@themarketingarm.com to request this Statement in an alternative format.