PMG Privacy Policy

Our Privacy Policy explains:

What information we collect and why we collect it.
How we use that information.
The choices we offer, including how to access and update information.

Information We Collect

We collect information to provide better experiences to all of our clients’ customers – from figuring out basic stuff like which language you speak, to more complex things like which ads you’ll find most useful, the products and services that matter most to you, or which digital experiences you may not yet be aware of but might enjoy.

PMG may collect personal user information via either our proprietary data management platform (DMP) tracking capabilities or direct data transfers from our clients. In general, the use of ‘our’ refers collectively to PMG and our clients. We collect information in the following ways:

Information we get from your use of our clients’ services. We receive information about the services that you use, how you use them, and the products that you purchase, like when you watch a video on YouTube, visit a website that uses our advertising services, or view and interact with our ads and content.
Information you give us. For example, many of our clients’ services require you to sign up for an account or provide credit card information. When you do, we may securely receive personal information, like your name, email address, telephone n umber or location information to store with your profile (however, our clients never provide PMG with your credit card number or other financial information). This information may include:
- Device Information
  We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). PMG may associate your device identifiers or phone number with other third-party vendors, like Google and Facebook.
- Log Information
  When you use our services or view content provided by PMG or our clients, we collect (or receive) and store certain information in server logs. This includes:
  - details of how you used our service, such as your search queries.
  - telephony log information like your phone number, calling party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.
  - Internet protocol address
  - device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
  - cookies that may uniquely identify your browser or device.
- Location Information
  When you use our services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide PMG with information on nearby devices, WiFi access points and cell towers.
- Local Storage
  We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
- Cookies and similar technologies
  We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services we offer to our partners, such as advertising services or PMG features that may appear on other sites.

Information we collect, in addition to information we obtain about you from partners, may be associated with your third-party accounts on properties like Google and Facebook. We treat all information associated with your PMG profile as personal information. For more information about how you can access, manage or delete information that is associated with your profile, visit the Transparency and Choice section of this policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or those of PMG’s clients or affiliates. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy (link to historical versions)).

How We Use Information We Collect

We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect our users. We also use this information to offer you tailored content – like giving you a more relevant ad experience and improving our businesses to better anticipate and meet your needs and desires.

We may use the personally identifiable information (PII) you provide across all of the services we offer. In addition, we may update past names and other PII associated with your PMG profile so that you are represented consistently across all our services.

We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Transparency and Choice

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:

View and edit your preferences about the Google ads shown to you on Google and across the web, such as which categories might interest you, using Ads Settings. You can also visit that page to opt out of certain Google advertising services.
Take information associated with your PMG profile out of many of our services.
Opt out of PII-targeted advertising.

You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us.

Information We Share

We do not share personal information with companies, organizations and individuals outside of PMG unless one of the following circumstances applies:

For external processing
We provide personal information to our affiliates or other trusted businesses or persons to process it for us, including for the purposes of creating and executing targeted advertising campaigns, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
For legal reasons
We will share personal information with companies, organizations or individuals outside of PMG if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms of Service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of PMG, our users or the public as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.

If PMG is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Information Security

We work hard to protect PMG and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

All personally identifiable information is hashed using the SHA-256 algorithm immediately upon receipt.
PMG relies upon the Amazon Web Services infrastructure for continuous auditing by security accreditation bodies, including ISO 27001, FedRAMP, DoD CSM, and PCI DSS.i.
PII is securely stored in an encrypted, distributed database, protected with Amazon’s Key Management Service.
Data stored on Amazon S3 is encrypted both at rest and in transmission using AES-256
Access to hashed PII is limited to PMG’s engineering group. Outside of engineering, only our proprietary applications may access hashed bulk files on behalf of PMG employees. Human access to raw PII is prohibited and restricted by our software.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the services offered by PMG and its affiliates, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, on social media, sites that may include display advertising, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Compliance and Cooperation with Regulatory Authorities

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks, including the EUUS Privacy Shield Framework. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ PII, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at https://www.pmg.com/contact/.

EU-US Privacy Shield Framework

To review PMG’s policies with regard to our participation in the EU-US Privacy Shield Framework, please visit https://www.pmg.com/privacy-policy/#privacy-shield-policy/.

Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how PMG and its subsidiaries and affiliates in the United States (“US”) (“Company,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Union (“EU Personal Data”). This Policy applies to the following US affiliated entities: Facebook, Google, SnapChat, Twitter, Pinterest. Thids Policy supplements our Website Privacy Policy located at https://www.pmg.com/privacy-policy/#privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

PMG recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about consumers, clients, and business received in the US, PMG has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). PMG adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, PMG is subject to the investigatory and enforcement authority of the US Federal Trade Commission and/or theUS Department of Transportation. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review PMG’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: [URL].

Personal Data Collection and Use

Our Website Privacy Policy located at https://www.pmg.com/privacy-policy/#privacy-policy describes the categories of EU Personal Data that we may receive in the US as well as the purposes for which we use that EU Personal Data. We process EU Personal Data for the following purposes: business-intelligence analytics, and targeted advertising. PMG will only process EU Personal Data in ways that are compatible with the purpose that PMG collected it for, or for purposes the individual later authorizes. Before we use your EU Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. PMG maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.

We may collect the following categories of sensitive EU Personal Data: personally identifiable information, to include: name, email, phone number, address, social media usernames, and data-subject behavioral information. When we collect sensitive EU Personal Data, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive EU Personal Data to third parties, or before we use your sensitive EU Personal Data for a different purpose than we collected it for or than you later authorized.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer EU Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy, including: business-intelligence analytics, data matching with other consumer-based databases, targeted advertising. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EU Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EU Personal Data that we transfer to them.

Third-Party Data Controllers. In some cases we may transfer EU Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your EU Personal Data to third-party data controllers for the following purposes: business-intelligence analytics, data matching with other consumer-based databases, targeted advertising. We will only provide your EU Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive EU Personal Data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for EU Personal Data the Privacy Shield requires. We also limit their use of your EU Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your EU Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EU Personal Data is protected with the same level of protection the Privacy Shield requires.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

PMG maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your EU Personal Data to us at https://www.pmg.com/contact/. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the EU data protection authorities. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities for further information and assistance.

Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with PMG and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your EU Personal Data, please contact us as follows: https://www.pmg.com/contact/

Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.

Effective Date: December 5, 2016
Last modified: December 5, 2016