PMG Worldwide, LLC Privacy Policy

Last Updated: May 14, 2018

Introduction

PMG Worldwide, LLC (“PMG” or “We“) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.
This Privacy Policy applies to pmg.com (the “Website”) which is owned and operated by PMG. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Website, and our practices for using, maintaining, protecting, and disclosing that information. This Privacy Policy also explains your options regarding the use, access and correction of your personal information. The use of information collected through this Website shall be limited to the following purposes of: (i) the reason for which you signed up to receive communications from PMG, and (ii) providing a service to you and other users of the Website (“Users”).

This Privacy Policy applies to information we collect:

• On or through this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by any third party that does not include links to this Privacy Policy; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Some of our clients provide PMG and its affiliates with personally identifiable information about their customers so we can perform various services such as online advertising campaign analysis. In addition, as part of our services, we may collect information about user interaction with client websites and provide that information along with our analysis to the client. All of this information belongs to our client and is governed by their privacy policy, and as their customer, you should review their privacy policies on their websites that you visit. PMG and its affiliates use such information only as directed by our client and we make no other use of this personally identifiable information.

Please read this Privacy 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. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy).

Information We Collect

We collect information to provide better experiences to the Users of this Website – 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 collects and processes two basic types of information from and about Users:

• Personal information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Users and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.
• Aggregate user and tracking information: This information gives us insights on how Users use our Website. This data is anonymous and does not contain any personal information. We use this information to ensure that our Website, e-mails and marketing efforts continue to appeal to Website visitors and clients.

This information is collected in the following ways:

• Information you Voluntarily Provide to PMG. PMG only collects personal information that you voluntarily provide, for example, when you use our “contact us” feature, sign up for a newsletter, post content within our forums or other interactive features. Examples of such personal information that you provide to us may include, among other information, your name, physical address and email address. Under such circumstances you consent to our use/processing of the information you provide consistent with this Privacy Policy.
• Cookies and Similar Tracking Technologies. When you visit the Website, PMG and its partners may use cookies or similar technologies to collect analytical information to analyze trends, administer the Website, track Users’ interaction with the Website, and to gather demographic information about our User base as a whole. Our Website uses cookies to distinguish you from other Users of our Website. This helps us to provide you with a positive experience when you browse our Website and also allows PMG to improve its Website and services. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Website. Every time you visit our Website Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We may also use third party analytical tools (e.g. Google Analytics) to analyze activities on the Website and use of the Website. You do not need to enable cookies to visit the Website; however, some parts of the website and some services may be more difficult or impossible to use if cookies are disabled. Some PMG cookie files remain on your computer’s hard drive unless and until you manually delete the file. PMG cookie files do not contain personal information. Please see PMG’s Cookie Policy for more information on PMG’s use of cookies on this Website and how you can disable or restrict the use of cookies.

Any personal information collected by PMG is controlled by PMG at its Fort Worth, Texas headquarters.

How we use Information we Collect

We use information that we collect about you or that you provide to us, including any personally identifiable information:

• To present our Website and its contents to you.
• To provide, maintain, protect and improve our services, to develop new ones, and to protect our Users.
• 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.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Website or any services we offer or provide through it.
• In any other way we may describe when you provide the information.

We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with PMG employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.

As discussed above, 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.

Information we Share

We may disclose aggregated information about our Users, and information that does not identify any individual (non-personally identifiable information), without restriction, including 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.

PMG does not share, sell or distribute personal information collected from Users with companies, organizations and individuals outside of PMG unless one of the following circumstances applies:

• For external processing. We may provide personal information to our subsidiaries and affiliates or other trusted businesses or persons to process it for us 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:
  o comply with any applicable law, regulation, legal process or enforceable governmental request.
  o enforce applicable terms of service, including investigation of potential violations.
  o detect, prevent, or otherwise address fraud, security or technical issues.
  o protect against harm to the rights, property or safety of PMG, our Users, our customers or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
• In connection with a PMG sale transaction. We may share personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PMG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PMG about our Website Users is among the assets transferred. If PMG is involved in such a transaction, 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.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was 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 in this Privacy Policy.

If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA. With respect to transfers of personal information to the U.S., PMG 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 information from the EEA to the U.S. Click http://www.pmg.com/privacy-policy/#privacy-shield-policy/ to view our EU-U.S. Privacy Shield Privacy Policy.

Transparency and Choice

People have different privacy concerns. Our goal is to be clear about what information we collect and how we use it, so that you can make meaningful choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies (including cookies associated with our services), or to alert you when cookies are being sent. To learn how you can manage your cookies on our Website, please see or Cookie Policy
• Google Ads. 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.
• Profile Information. Take out any of your personal information associated with any PMG profile.
• Targeted Advertising. If you do not want us to use personal information that we collect or that you provide to us to deliver advertisements according to our target-audience preferences, you can opt-out by selecting “decline” on our cookie notice banner. If you previously accepted cookies on our website and want to opt-out, please clear your cookies and select “decline” on our cookie notice banner. For browser specific cookie settings and instructions please see our Cookie Policy.

Notwithstanding anything contained herelin, you may ask us to delete any information about you and cease further contact at any time by sending us a request marked “Privacy-Urgent”.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

At times, our Website may provide interactive areas, such as chat rooms, forums and message boards available to Users. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

Accessing and Correcting your Information

You may contact us at http://www.pmg.com/contact/ to request access to, to correct, to update or to delete any personal information that you have provided to us. To protect your privacy and security, we will also take reasonable steps (including seeking additional information or documentation) to verify your identity before updating or removing your information. Upon receiving your email with the request to update or remove your information, our privacy team will log the receipt of your request and will contact the appropriate data holder within the company in order to enable them to process your request. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Information Security

PMG understands that the safety of your personal information is extremely important to you. Accordingly, we work hard to protect PMG and our Users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 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.
• Personally-identifiable information 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 personally-identifiable information 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 personally-identifiable information is prohibited and restricted by our software.

Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and PMG expressly disclaims any such obligation.

Links to Other Websites

Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the privacy practices and the protection and privacy of any information which you provide while visiting such sites. Such sites are not governed by this Privacy Policy. You should exercise caution and carefully review the privacy policy applicable to the website in question.

When this Privacy Policy Applies

Our Privacy Policy applies to your use of the Website and 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 EU¬US Privacy Shield Framework described below. 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.

Provisions Applicable to International Users

Information provided through this Website may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Website, you consent to the transfer, processing and/or use of the information globally throughout PMG. Wherever the information is transferred or accessed within PMG it will be processed and used in accordance with this privacy policy.

PMG has self-certified with the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries in connection with the Privacy Shield Principles as part of the Privacy Shield program. To learn more about the Privacy Shield program, and to view PMG’s certification, please visit http://www.privacyshield.gov. To review PMG’s policies with regard to our participation in the EU-US Privacy Shield Framework, please visit http://www.pmg.com/privacy-policy/#privacy-shield-policy/.
In compliance with the Privacy Shield Principles, PMG commits to resolve complaints about our collection or use of your personal information. PMG is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Further, with respect to citizens to the European Union PMG has agreed to cooperate in investigations by, and comply with the advice of, the Federal Trade Commission and appropriate EU data protection authorities (“DPA”) in managing and resolving any dispute or complaint and provide the relevant DPA with written confirmation of the action taken. If you have questions or complaints regarding the use or disclosure of personal information in compliance with the principles of this privacy policy, you should contact us first at http://www.pmg.com/contact/ and we will contact you promptly to attempt to resolve your concerns or complaint. If contacting us does not resolve your concern or complaint, you may raise your complaint with the relevant DPA where you live or work (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm for contact information). As further explained in PMG’s Shield Policy, a binding arbitration option is available in the event that residual complaints are not resolved by any other means.

Changes to our Privacy Policy

As we provide more services and/or functionality on our Website and as privacy laws and regulations evolve, it may be necessary to revise or update 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’ Personal Information, 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 Privacy 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, 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 http://www.pmg.com/contact/.

Applicable Law

This Privacy Policy will be governed by, and construed in accordance with, the laws of the state of Texas, without regard to principles of conflict of laws, and the EU-U.S. Privacy Shield framework.

Disputes

Unless the EU-US Privacy Shield framework require otherwise, you and Company (a) will submit any dispute relating to this Privacy Policy exclusively to a federal, state or local court located in Tarranty County, Texas and having subject matter jurisdiction over such dispute, and (b) consent to any such court being a proper venue, and waive any objection to its not being a proper venue (including, but not limited to, any such objection based on convenience), for such dispute. For any dispute relating to personal information covered by the EU-US Privacy Shield framework, an independent recourse mechanism may be available to you to investigate any unresolved complaints regarding Company’s compliance with those frameworks. If you have a complaint, or desire additional information, regarding Company’s handling of personal information or otherwise relating to this Privacy Policy, you should promptly contact Company as set forth below.

Severability

Whenever possible, each provision of this Privacy Policy shall be interpreted to be effective and valid under applicable law. If, however, any such provision shall be prohibited by or invalid under such law, it shall be deemed modified to conform to the minimum requirements of such law, or if for any reason it is not so modified, it shall be prohibited or invalid only to the extent of such prohibition or invalidity without the remainder of such provision, or any other provision of this Privacy Policy, being prohibited or invalid.

Contact Us

If you have any questions, complaints or desire additional information regarding PMG’s handling of personal information or otherwise relating to this Privacy Policy, please promptly contact us at: http://www.pmg.com/contact/

PMG WorldWide, LLC
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. This Policy supplements our Website Privacy Policy located at http://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 the US 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: https://www.privacyshield.gov.

Personal Data Collection and Use

Our Website Privacy Policy located at http://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 company 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 http://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: http://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: May 14, 2018