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Crossmedia Privacy Policy

Overview

Crossmedia, Inc. (“Crossmedia”) takes privacy and data security seriously. We are committed to clearly informing visitors about the collection and use of their information when using our services. As a result, we have put together this Privacy Policy to explain how we collect, use and disclose certain information. This Privacy Policy only applies to our website and service located at xmedia.com (the “Web site”). This Privacy Policy does not apply to any other product, service or website of ours or our clients. With respect to the personal information that our clients and their vendors we may collect from you outside of our Web site and provide to us via use of our services for our clients (“Service Data”), where permitted by law, we generally process such information only as a “service provider” or “data processor” (as those terms are defined under applicable data protection laws) on behalf of our clients, who act as the “business” or “data controller” (as those terms are defined under applicable data protection laws). Our clients are the parties that control the use of the Service Data and determine the purposes for which we process such information. While this Privacy Policy describes how we process Service Data on behalf of our clients, our clients are responsible for their own practices in collecting, using, and disclosing information they collect from you. To learn more about such clients’ use of your information and your rights that you may have over such information, please consult the privacy policy of the applicable company or publisher with whom you interact. Certain rights under this Privacy Policy only apply based on your country of residence. Please see the sections below titled California Privacy Rights; Virginia, Colorado, Connecticut and other U.S. State Privacy Rights; and EU Data Subject Rights.

Collection of Personal Information

When using the Web site, you may be asked to provide, or you may choose to upload, certain personally identifiable information about yourself (“Personal Information”). Personal Information can include your name, email address, physical address and other information that specifically identifies you. Categories of Personal Information we collect include:

  • Identity Data, which includes name or other similar identifiers.
  • Contact Data, which includes address, email address and telephone numbers.

We will never collect Identity Data or Contact Data directly from you through this Web site unless you have voluntarily provided it to us.

Collection of Non-Personal Information

In addition, we may also collect non-personally identifiable information which does not specifically identify you (“Non-Personal Information”). Non-Personal Information may include information regarding your use of the Web site, such as IP host address, pages viewed and other click-stream data. Non-Personal Information may be automatically collected by us from you without any separate notice other than this Privacy Policy.

Cookies and Similar Technology:

We and our third party providers may store some information on your device as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies) to collect Non-Personal Information related to usage of the Web site. "Cookies" are pieces of information that may be placed on your device by a web site for the purpose of collecting data to facilitate and enhance your communication and interaction with that web site. Such data may include, without limitation, the address of the websites you visited before and after you visited the Web site, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Web site you visit and what links you clicked on, the region where your device is located, and geo-IP data. We may use cookies to customize your visit to the Web site and for other purposes to make your visit more convenient or to enable us to enhance our service.

An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click here.

We may use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Web site.
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Web site when they are using it. This helps us to improve the way our Web site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognize you when you return to our Web site. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our Web site, the pages you have visited and the links you have followed. We will use this information to make our Web site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose More information
Google __gsas
__gpi
__gpi_optout
NID
DSID
id
__gads
GED_PLAYLIST_ACTIVITY
ACLK_DATA
FPAU
ANID
AID
IDE
TAID
FPGCLDC
_gcl_dc
_gcl_au
FLC
RUL
FPGCLAW
FPGCLGB
_gcl_gb
_gac_gb_ wpid
_gcl_aw
1P_JAR
Conversion
VISITOR_INFO1_LIVE
VISITOR_INFO1_LIVE__k
VISITOR_INFO1_LIVE__default
_gac_ wpid
_gcl_gf
_gcl_ha
PAIDCONTENT
APC
These cookie enables us to:
(a) Estimate website audience size and usage pattern.
(b) To deliver, measure and improve the relevancy of ads.
(c) Securely recognize you when you return to our site.
(d) Help deliver an optimal experience for your device’s screen.
(e) Store your advertising preferences
https://business.safety.google/adscookies/?hl=en_US
Meta _fbp; _fbc
c_user; xs
dpr; wd
fr
oo
sb; dbln
These cookie enables us to:
(a) Estimate website audience size and usage pattern.
(b) To deliver, measure and improve the relevancy of ads.
(c) Securely recognize you when you return to our site.
(d) Help deliver an optimal experience for your device’s screen.
(e) Store your advertising preferences
https://www.facebook.com/privacy/policies/cookies/?annotations%5b0%5d=explanation%2F1_common_cookies_and_uses
Linkedin bcookie
bscookie
JSESSIONID
lang
lidc
sdsc
li_gc
li_mc
UID
UserMatchHistory
AnalyticsSyncHistory
lms_ads
lms_analytics
li_fat_id
li_sugr
_guid
BizographicsOptOut
li_giant
oribi_cookie_test
oribili_user_guid
ln_or
UserMatchHistory
lms_ads
li_sugr
_guid
A3
anj
uuid2
usersync
icu
uids
dpm
dextp
demdex
dst
lnkd
aam_uuid
MUID
MR
IDE
fr
personalization_id
GUC
B
test_cookie
_gcl_au
_gcl_aw
_gcl_dc
brwsr
ABSELB
IRLD
barometric[cuid]
tluid
oribi_cookie_test
oribili_user_guid
uids
l_page
_rdt_uuid
lms_analytics
AnalyticsSyncHistory
queryString
SID
VID
UID
UIDR
AMCVS_14215E3D5995
C57C0A495C55%40AdobeOrg
AMCV_14215E3D5995C5
7C0A495C55%40AdobeOrg
s_cc
s_sq
s_vi
s_fid
ki_r
ki_s
ki_t
ki_u
gpv_pn
s_plt
s_tslv
s_ppv
s_pltp
s_ips
s_tp
oribi_cookie_test
oribili_user_guid
ln_or
QSIPopUnder_PopUnderTarget_SI_id
QSI_HistorySession
QSI_SI_id_intercept
QSI_S_ZoneID
QST
PageReferrer
ActionSetHistory
FocusTime
SearchTerm
SiteReferrer
gdpr
cnac
cip
cf
car
callback
_clck
_clsk
These cookie enables us to:
(a) Estimate website audience size and usage pattern.
(b) To deliver, measure and improve the relevancy of ads.
(c) Securely recognize you when you return to our site.
(d) Help deliver an optimal experience for your device’s screen.
(e) Store your advertising preferences
https://www.linkedin.com/legal/l/cookie-table

Legal Basis and Use of Personal Information

We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the circumstances listed below. Except as described below, we do not share your Personal Information with any third party.

  • We may use your Personal Information from time to time to send you newsletters and other information about Crossmedia and to retarget advertising to you.
  • We may use your Personal Information to respond to your questions or to provide service you have requested and to operate our service.
  • We may provide your Personal Information to our subcontractors, vendors and service providers only for use in connection with services they are performing on our behalf.
  • We may transfer your Personal Information in connection with the sale or merger, in whole or in part, of Crossmedia, its assets or the division responsible for the applicable services, or a corporate reorganization or bankruptcy proceeding.
  • We reserve the right to access and/or disclose Personal Information and Non-Personal Information we gather as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Web site’s policies, or the rights of third parties or to investigate any suspected conduct which we deem improper.

Please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent. Finally, we reserve the right to supplement your Personal Information with information we gather from other sources which may include information we gather from online and offline sources.

We are the data controller and are responsible for your Personal Information.

Use of Non-Personal Information

We may use and share Non-Personal Information to improve and enhance your experience on the Web site and for any other business activities. For example, we may share Non-Personal Information with unaffiliated third parties, such as business partners.

Links to Third Party Services

This Web site may contain links and interactive features with various third parties. If you already use these platforms, their cookies may be set on your device when using our Web site which allows them to recognize you through identifying tools including cookies. You should review the privacy practices of those third party and social media services since we do not control how they collect or use your information.

Data Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We will delete your Personal Information upon written request as set forth in this Privacy Policy. Even if we delete some or all of your Personal Information, we may continue to retain and use anonymous data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Security Practices

We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on the Web site or our servers, will be completely free from unauthorized access by third parties such as hackers and your use of the Web site demonstrates your assumption of this risk.

Interest-Based Advertising

We believe that advertising is more effective and valuable to you when it is targeted to your general interests and behaviors. Therefore, we may work with third parties who collect information on our Web site and elsewhere through the use of cookies and similar methods in order to serve you with relevant advertisements on other services or to determine that you have seen our advertisements on other services. For example, if you view information on our Web site about certain types of services, we may target advertising to you on other websites and services (such as unaffiliated websites and social media services) about such types of services. This method of advertising is sometimes called “interest-based advertising.”

You do have the ability to control certain advertising practices. You can learn more about interest-based advertising and opt-out of targeted advertising from certain providers who comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA)by visiting the DAA’s consumer choice page. The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. However, if you are a resident of jurisdiction that requires by law that we honor certain user-preference signals such as Global Privacy Control signals, we will treat those as a means of opting out of the sale or sharing of personal information, or of opting out of the processing of personal information for targeted advertising, as applicable.

For targeted advertisements delivered through mobile Apps, you can install the DAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices).

No Children under age 13

We have no intention of collecting Personal Information from children under the age of 13. When we become aware that Personal Information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.

Changes to Privacy Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use previously collected Personal Information in a way that materially differs from this Privacy Policy, we will provide you the opportunity to opt-out of such differing uses. All changes to this Privacy Policy we will be posted here. Your continued use of the Web site following the posting of any changes to this Privacy Policy means you accept such changes.

Data Access, Your Choices & Opt-Out

We provide you with choices regarding the information you provide to us.

  • Personal Information - If you would like to delete or modify your Personal Information, or to receive a copy of your Personal Information, you may contact us at legal@xmedia.com.
  • Browsing Information - You may stop or restrict the placement of cookies on your device or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Web site, but it may interfere with some of its functionality. Further information on cookies is available at www.allaboutcookies.org.
  • Interest-based Advertising - You can opt-out of certain targeted advertising by following the instructions in the Interest-based Advertising section above.

We are not responsible for removing your information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy.

California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020, provides you with specific rights regarding your personal information. This section describes the rights that California consumers have and explains how to exercise those rights. These rights are granted only to the extent that you are a California consumer and we are acting as a “business” under the CCPA with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA.

Information We Collect; How We Collect It; How We Use It

General information regarding our collection, use, and disclosure of personal information is set forth in the Privacy Policy above.

In the past 12 months, we have collected the categories of personal information described in Table 1 below for the business or commercial purpose(s) indicated.

Categories of Personal Information

Category Examples Purpose(s)
Internet or other similar network activity information Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement To provide you with our services and to enhance our services.
Internet or other similar network activity information Browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement To provide you with our services and to enhance our services.
Geolocation data General/non-precise location tracking information To provide you with our services and to enhance our services.
Professional or employment-related information Employer, employment history, resumes and CVs, background checks, and other employment-related information To evaluate your application for employment and to manage your employment.

How We Use and Disclose Your Personal Information

Category Source Disclose(d) to Sell/Sold to Share(d) with
Identifiers Directly from consumers when interacting with our services Vendors, service providers and other third parties With third parties helping with retargeting advertising to you With third parties helping with retargeting advertising to you
Internet or other similar network activity information Directly from consumers when interacting with our services Vendors, service providers and other third parties With third parties helping with retargeting advertising to you With third parties helping with retargeting advertising to you
Geolocation data Directly from consumers when interacting with our services Vendors, service providers and other third parties With third parties helping with retargeting advertising to you With third parties helping with retargeting advertising to you
Identifiers Directly from consumers when interacting with our services Vendors, service providers and other third parties With third parties helping with retargeting advertising to you With third parties helping with retargeting advertising to you

Disclosure of Personal Information

We may disclose your personal information to a third party for a business purpose, or sell or share your personal information, subject to your right to opt out (see Personal Information Sales Opt-Out and Opt-In Rights, below). The information above under Information We Collect; How We Collect It; How We Use It describes the entities with which we may disclose your personal information.

Rights to your information

a. Right to Know

As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

  • The categories of personal information we collected about you.
  • The categories of sources from which the personal information is collected.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (see Data Portability Rights below).

b. Right to delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we maybe retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

c. Right to Data Portability

You have the right to request a copy of personal information we have collected and maintained about you. The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.

d. Right to Correct

You have the right to request the correction of any personal information we maintain about you.

e. Right to Opt Out of Selling or Sharing Your Personal Information

You have the right to opt out of the sale or sharing of your personal information, along with the right to opt in to the sale of such information. We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is less than 16 (but greater than 13) years of age, or the parent or guardian of a consumer less than 13 years of age. To our knowledge, we do not sell or share the personal information of minors under 16 years of age. To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page: "Do Not Sell or Share My Personal Information/Opt-out." We will also treat Global Privacy Control browser signals as valid opt-out requests.

f. Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

g. Exercising Your Rights

To exercise the rights described above, please contact us by using the following methods:

  • Emailing us at legal@xmedia.com
  • Visiting our consent and opt-out page here.

After submitting certain requests, we may take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we may ask that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request. Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we may ask you to submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf, such as a signed document.

Virginia, Colorado, Connecticut and other U.S. State Privacy Rights

Residents of Virginia, Colorado, Connecticut and eventually Utah, Iowa, Indiana, Tennessee and other U.S. States with comprehensive consumer privacy laws (“States”) have certain rights with respect to their personal information. The rights available to residents of these States are explained below, and vary based upon the State Laws applicable to us and to you. Such laws and being enact and modified on a regular basis, so these rights are evolving. The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the details of our Privacy Policy above.

Rights to your information

In addition to the rights set forth in our Privacy Policy, the State Laws provide you with the following rights, except where indicated otherwise below:

  • Right to know. You have the right to know whether we process your personal information and to access such personal information.
  • Right to data portability. You have the right to obtain a copy of your personal information that you previously provided to us or that we have obtained in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. Subject to certain exceptions, you may request such personal information free of charge once annually, except for Virginia residents, who may request such personal information up to twice annually.
  • Right to delete. You may have the right to delete personal information that you have provided to us or that we have obtained about you. Please note that we may deny requests to delete if the requested deletion falls under an exception as set forth the applicable State Laws. Additionally, if you request deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the applicable State Laws.
  • Right to opt out. You may have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling that produces legal or similarly significant effects concerning you.

As of the latest date of the Privacy Policy:

  • We do process personal information for the purposes of targeted advertising
  • We do not sell your personal information in exchange for monetary consideration; and
  • We do not engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you

If you wish to opt out of the processing of your personal information for any of the above purposes, and your state of residence provides for such opt-out right, please click here.

  • Right to correct. Residents of certain states have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it.
  • Right to nondiscrimination You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights.

Rights to your information

To exercise the rights described above, please contact us by using the following methods:

  • Emailing us at legal@xmedia.com
  • Visiting our consent and opt-out page here.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.

Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the certain State Laws allow an extension of our time to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and, for Virginia, Colorado and Connecticut residents, provide instructions for how to appeal the decision. Residents of those will have the right to appeal within a reasonable period of time after you have received our decision. Within the time provided by your State Law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state’s regulatory authority to submit a complaint.

EU Data Subject Rights

If you are a situated in the EU, UK or Switzerland under the General Data Protection Regulation and similar laws in such countries (“GDPR”), as a data subject, you have the following rights:

  • Right to access – This right allows individuals to obtain confirmation as to whether or not Personal Information concerning him or her is being process and provide access to such Personal Information. It also allows individuals to request details of the processing of his or her Personal Information, including, without limitation, categories of recipients to whom the Personal Information have been or will be disclosed and purposes of processing.
  • Right to rectify – This right allows individuals to rectify any inaccurate Personal Information about him or her.
  • Right to restrict processing – This right allows individuals to block or suppress processing of Personal Information under certain circumstances.
  • Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have Personal Information erased or to prevent processing in specific circumstances.
  • Right of data portability – This right allows individuals to move, copy or transfer Personal Information from one place to another in a secure manner without interrupting the integrity and usability of the information.
  • Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

Additionally, if we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To exercise your rights under the GDPR, please contact us at legal@xmedia.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more Personal Information from you than we currently have.

If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.

Cross Border Transfers

Our Web site is maintained in the United States of America. By using the Web site, you authorize the export of Personal Information to the USA and its storage and use as specified in this Privacy Policy. We transfer Personal Information from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Information stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. Personal Information of data subjects within the EU will be transferred in compliance with the requirements of the GDPR.

Our Terms of Use

Use of the service through our Web site is governed by, and subject to, Terms of Use. Your use, or access, of the Web site constitutes your agreement to be bound by these provisions.

Contact

For questions or concerns relating to privacy, we can be reached at legal@xmedia.com.

Effective Date

This Privacy Policy was last updated on September 19th, 2023.