Privacy Statement

SandMark Media, LLC Privacy Policy

Last Updated: October 21, 2020

This Privacy Policy describes the privacy practices for the websites operated by SandMark Media, LLC and its affiliates (“SandMark” “we”, “our” “us”), and applies solely to the Personal Information (as defined below in Section 1) that we collect and use relating to consumers and users residing outside of the State of Michigan.

This Privacy Policy is applicable to the publications, businesses, websites and mobile applications operated by SandMark Media/EUP News, including the Website from which you accessed this Privacy Policy. It also applies to the related online services that we provide through our Websites and mobile apps (the “Services”).

By using the Websites and/or the Services and providing us with Personal Information, you agree to the practices described in this Privacy Policy and the Cookie Policy referenced below and to the updates to these policies posted here from time to time. To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Last Updated” date shown above.

1. Definition of Personal Information

For purposes of this Privacy Policy, unless a different definition is noted in a particular instance, “Personal Information” means information that identifies, relates to, describes, references, or is reasonably capable of being associated with a particular consumer or device.

2. Personal Information We Collect

We may collect the following types of Personal Information as described below:

(A) Personal Information you provide to us,
(B) Personal Information we may automatically collect, and
(C) Personal Information we may receive from third parties.

A.Personal Information You Provide to Us

In using our Websites or Services, you may provide us with Personal Information, which may include (the examples provided are illustrative and not intended to be exhaustive):

Contact information such as name, email address, postal address and telephone number(s);
Demographic information such as birth date or gender;
Account information and log in credentials, including unique identifiers such as username and password;
Payment and transaction information including credit or bank card information;
Preferences for communications;
Communications and opinions in chat rooms, message boards, forums, surveys, polls, and online forms;
Access to your geo-location (including through our mobile app) or to other data held on social media platforms and other software (for example, access to your contacts, calendar or photos);
Photos and/or videos; and
Additional information as otherwise described to you at the point of collection or pursuant to your consent.

B.Personal Information We May Automatically Collect About You

Our Website and Services may automatically collect certain Personal Information about you. This Personal Information may include (the examples provided are illustrative and not intended to be exhaustive):

IP address, which is the number associated with the service through which you access the Internet, such as through your ISP (Internet service provider);
Date and time of your visit or use of our Websites or Services;
Domain server from which you are using our Websites or Services;
Type of computer, web browsers, search engine used, operating system, or platform you use;
Data identifying the web pages you visited prior to and after visiting our Websites or using our Services;
Your movement and activity within the website, which is aggregated with other Personal information;
Geo-location information through the use of any of our mobile applications;
Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

C.Personal Information We May Receive from Third Parties

We may collect additional Personal Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, SnapChat (“Social Media Platforms”), third party data providers, and sources providing publicly-available Personal information (e.g., from the U.S. postal service) for the purposes described in Section 3 below.

Personal Information we may access from Social Media Platforms may include, but is not limited to:

your Social Media Platform login information
your location data
your profile information
your list of contacts, friends or followers
certain Personal Information about your activities on the Social Media Platform

Please keep in mind that when you provide Personal Information to us on a third-party website or platform (for example, via our applications), the Personal Information you provide may be separately collected by the third-party website or the Social Media Platform. Please review the privacy policies of the applicable third party website or Social Media Platform for their privacy practices.

3. How We Use Personal Information

A.Use and Purpose of Processing Your Personal Information

We use and process your Personal Information for the following types of purposes (the examples provided are illustrative and not intended to be exhaustive).

To provide you with the Websites and Services, and related promotions, newsletters and information you request
To respond to your inquiries and provide you with requested information and other communications, including by email or text messages, and including alerts, notification of promotions, contests, and events
For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications
For billing and payment processing
To deliver personalized advertising and content
To fulfill contracts we have with you
To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners
To maintain, improve, customize, or administer the Websites and Services, perform business analyses, or other internal purposes to improve the quality of our business, the Websites and the Services, resolve technical problems, or improve security or develop other products and services
To comply with our Terms of Use
To perform analytics for business purposes and business intelligence, such as monitoring traffic to our Website, counting ad impressions, and auditing legal and regulatory compliance
To maintain the safety, security, and integrity of our Website, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators
To identify and repair errors in our Website’s functionality
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred
To comply with any applicable laws and regulations and respond to lawful requests; and/or
For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent

If we decide to use the Personal Information for materially different purposes, we will update this Privacy Policy.

B.Disclosing Your Personal Information to Other Parties

We may disclose your Personal Information to other parties, including:

Our affiliates
Service providers
Advertisers, advertising technology companies, analytics companies and other third parties with whom we have business relationships
Government regulators
Our legal advisors and parties involved in a legal process
To an entity involved in the sale of our business
Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you

In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect Personal Information when you use our Websites (such as the IP address of your device, the identifier on your mobile device, or cookies stored on your device), and may share the information we collect with third parties. Please see our Cookie Policy for more information.

If we decide to disclose Personal Information to additional categories of parties, we will update this Privacy Policy.

4. DO WE USE “COOKIES”?

Yes. Cookies and similar technologies are small files that a website or its service provider transfers to a computer’s hard drive through a Web browser (if the user allows) that enables the website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information.

In general, we and our third party providers and advertisers, use cookies and other technologies to optimize the functionality of the Websites, to help us understand how the Websites are used and to provide users with interest-based content or advertising based upon their browsing activities and interests.

For more information about the cookies and other technologies that we, our affiliates and third party providers and advertisers use on our Websites, please read our Cookie Policy.

5.THIRD PARTY LINKS

Our Websites or Services may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms, or may redirect you off our Website or away from our Services to other websites for information or other services. This Privacy Policy only applies to information collected by our Websites and Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

6. SECURITY

We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly Contact Us so that necessary measures can quickly be taken.

7. ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION

As required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified consumer request you submit with respect to your Personal Information. Please submit a verifiable consumer request to us through the web form link provided below in Contact Us.

9. CHILDREN’S ON-LINE PRIVACY INFORMATION

The Websites and Services are not intended for use by children under the age of 13. In addition, we do not knowingly collect information from children under the age of 13, although certain third party sites that we link to may do so. These third-party sites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Websites without their permission.

Involvement of parents: In accordance with the provisions of the Children’s Online Privacy Act, in the event that we do begin collecting any Personal Information or data from children under the age of 13, we will notify parents first, and will seek parental or guardian consent to collect, use and/or disclose certain Personal Information from children under the age of 13. A parent may review and have deleted their child’s Personal Information, and may refuse to permit further collection or use of their child’s information by contacting us as noted at the end of this Privacy Policy. Parents may consent to our collection and use of their child’s Personal Information without consenting to the disclosure of that information to others.

If you have reason to believe that a child under the age of 13 has provided Personal Information “Contact Us” below with sufficient detail to enable us to delete that information from our databases.

10. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our Websites and update the notice’s “Last Updated” date. Your continued use of our Website and/or Services following the posting of changes constitutes your acceptance of such changes.

11. CONTACT US

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information described here, your choices and rights regarding such use, or you wish to exercise your rights, please contact us.

Call us at +1 (906) 203-1206
Email us at privacy@eupnews.com