Last Updated: June 30, 2018

Introduction
MediaValet Inc. (“MediaValet”, “us”) as well as its affiliates, are committed to protecting the privacy of all individuals (“users”, “you”) who:

  • visit MediaValet’s website located at mediavalet.com which includes all subdomains, present and future (the “Website”);
  • use the web, desktop, and mobile applications that MediaValet makes available from time to time (the “Applications”); and
  • use the MediaValet services including the MediaValet portal and other MediaValet products and services (the “Products”).

To make this policy easier to read, we call the Website, the Applications and the Products together the “Services”.

It is MediaValet’s policy to respect your privacy and the privacy of all users of the Services. This Privacy Policy has been established to help you understand our commitment to protecting your privacy and personal information, and the steps we take to ensure it. By visiting and/or using any of the Services, you agree to be bound by the terms of the present Privacy Policy (the “Privacy Policy”). Where the present Privacy Policy refers to MediaValet, it may refer to the Services or to MediaValet Inc., depending on the context.

MediaValet reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at www.mediavalet.com/privacypolicy. Please check the Privacy Policy periodically for changes, though we reserve the right to notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Services or the handling of your personal information. Your use of the Services following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.

MediaValet ’s Privacy Policy forms part of its wider terms of service that also include our Terms and Conditions. These can be found at www.mediavalet.com/termsandconditions. Together, our Terms and Conditions and our Privacy Policy apply to your use of the Services.

About this Privacy Policy
This Privacy Policy applies to the handling of personal information and other non-identifiable information gathered by MediaValet when you are using or accessing the Services.

This Privacy Policy does not apply to any applications or websites developed by third parties that MediaValet does not own or control (“Third-Party Apps”).

  1. Personal Information We May Collect and Use

i) Personal Information We Collect at Registration and from Subscribed Users
When you first register for a MediaValet account and then update your user profile, we may collect some personal information about you such as:

  • your full name, username, and email address;
  • your password, in connection with your account and your log-in facility;
  • the geographic area where you use your computer and mobile devices; and
  • other optional information as part of your account profile.MediaValet uses the collected information for the following general purposes:
  • to provide you with the Services, including upgrades and related services, which you have requested from us; and
  • to keep you informed of information about our Services we think you may find useful.By submitting information to MediaValet when registering, you consent to the use of your information for these purposes in accordance with this Privacy Policy.

ii) Personal information You Submit to Us Voluntarily
MediaValet may gather personal information, such as your name, username, business address, job title, department, phone number and email address via various methods (phone, email, online forms, in-person meetings) when you voluntarily communicate such information to us. MediaValet may use such personal information for sales, marketing, and support of the Services. This personal information is never shared with third parties.

iii) System and Device Information
MediaValet automatically collects and receives certain information from your computer or mobile device, including the activities you perform when using the Services, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable) (collectively referred to as “traffic data”). We may link this traffic and usage data to your unique MediaValet user ID to better understand your needs and the needs of users in the aggregate, diagnose problems, analyze trends, provide services, improve the features and usability of our Services, and better understand and market to our customers and website users.

MediaValet also makes use of non-identifiable information gathered for statistical purposes in aggregate form to keep track of the number of visits to the Services and Website pages with a view to introducing improvements and improve usability of our Services. We may share this type of statistical data so that our partners also understand how often people use our Services, so that they, too, may provide you with an optimal experience.

Your IP address and relevant non-identifiable information may be used in order to trace any fraudulent or criminal activity or any activity in violation of the Terms.

iv) Information Collected Through Cookies and Related Technologies
MediaValet uses tracking technology (“cookies”) on the Website, in the Applications, and in the Products. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text files placed on your device when you visit a web site, in order to track use of the Services and to improve your user experience.

(a) Session Cookies
The Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your log-in session so you can move easily within the Website or the Services. Without these cookies, we wouldn’t be able to provide the Services to you. These session cookies have limited functionalities and expirations, and you will be required to re-enter your MediaValet log-in information after a certain period of time has elapsed to protect you against others accidentally accessing your account contents and related personal information.

(b) Google Analytics
MediaValet uses a specific cookie in order to facilitate the use of Google Analytics for users using the Services. If you are a returning visitor, MediaValet may use Google Analytics to track and analyze the pages of the Services you visit.  We do this only to better understand how you use the Services, with a view to offering improvements for all MediaValet users; and to tailor our business and marketing activities accordingly, both generally and specifically to you. Google Analytics cookies do not provide MediaValet with any personal information.

Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.

(c) Google Display Advertising
Additionally, MediaValet uses Google Analytics code that allows for certain forms of display advertising and other advanced features. Subject to change, the Google Display Advertising features MediaValet may use are Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting.

These features are used to advertise online; to allow third-party vendors, including Google, to show you advertising across the Internet; to allow MediaValet and third-party vendors, including Google, to use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Website and to report how ad impressions, uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Website. Data from Google’s interest-based advertising or third-party audience data (such as age, gender, and interests) is also combined with Google Analytics to better understand the needs of MediaValet users and to improve the Services.

You may opt out of such display advertising at any time by visiting your Google Ads Settings page or by installing and running the Google Analytics Opt-out Browser Add-on.

MediaValet may also use web beacons, bugs, pixels, and software tokens in order to facilitate your use of the Services.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies. Further information can be found at http://www.networkadvertising.org/managing/opt_out.asp.

Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Services. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.

  1. How We May Share Your Personal Information
    Except as provided in the next paragraphs and elsewhere in this Privacy Policy, MediaValet does not divulge any personal information gathered via the Services to third parties.Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or that you have submitted:

i. to third parties who provide us certain services, for example to provide website and software hosting and support services, to process transactions, to facilitate provision of the Services or for marketing purposes. Such service providers are only permitted to access and use personal information necessary to provide such services. They are required to protect your personal information and must agree to adhere to this Privacy Policy;

ii. when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;

iii. where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;

iv. if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;

v. if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);

vi. to a parent company, subsidiaries, joint ventures, or other companies under common control with or by MediaValet;

vii. if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy); and

viii. if this information is not private, is aggregated or is otherwise non-personal information, such as your public user profile information and related public data (such as Tweets, likes, etc.) or the number of users who clicked on a particular link (even if only one did so).

  1. Transfer of Personal Information
    MediaValet may transfer your personal information to third party service providers and affiliates located abroad, including in the United States. These service providers assist us with the operation of the Website and the provision of our Services as well as with our marketing and business communications effort. As a result, your personal information may be accessed by the courts, law enforcement and public authorities of such countries pursuant to local legislation.
  1. Children
    Protecting the safety of children when they use the Internet is very important to us.  Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean different ages in different countries, depending on where the individual accesses the services. By default, MediaValet considers such Minimum Age to be 18 years old.  However, if applicable law requires that you must be older than 18 in order for MediaValet to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.
  1. Security
    MediaValet has implemented reasonable technical, organisational and administrative measures to protect your data from unauthorized access, loss or theft, modification and other threats. Personal information is protected by security safeguards that are appropriate to the sensitivity level of the information. This includes the use of SSL and TLS.Our employees, affiliates and third party providers are required to sign contracts obliging them to protect the privacy and confidentiality of personal information provided to them, and is to observe the intent of this Privacy Policy, in order to perform their function. This obligation remains in effect even after employees, affiliates and third party services providers leave the employ of or association with MediaValet. Appropriate controls are in place over computer systems and these controls are reviewed on an ongoing basis to ensure compliance with this Privacy Policy.
  1. Email preferences
    MediaValet uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You can manage your email preferences, such as opting-out or unsubscribing from emails sent by contacting support@mediavalet.com. You may also opt out or unsubscribe from any future email communications from using a link provided in each email correspondence that we send you.
  1. Your rights
    You can contact our Privacy Officer to obtain a copy of the personal information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct and, where relevant, erase that information. Please note that certain personal information may need to be retained by MediaValet for a period of time following cancellation of your account where this is necessary for our legitimate business purposes or required by applicable law. As mentioned above you have a right to change your email preferences at any time.
  1. Additional terms applicable to data subjects in the European Union
    If you are in the European Union, please note that this section applies to our processing of your personal information in addition to the other terms of this Privacy Policy. Any reference to “personal information” in this Privacy Policy should be understood as referring to “personal data”,  defined under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.MediaValet collects personal information about you. MediaValet as data controller processes your personal information in compliance with the requirements of the GDPR, as amended from time to time.
  • Legal bases upon which we process your Personal Information

We only process your personal information:

 with your consent;
 for performing the Services you have requested from us or, upon your request, to take the
steps necessary to provide you with such Services; or
 in the furtherance of our legitimate interests in maintaining business relationships and communicating with you as a business contact, about MediaValet’s activities and services. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you want to, please contact our Privacy Officer at the contact details indicated below.

  • Retention of your personal information

We only retain your personal information for as long as necessary to fulfill the purposes identified in this Privacy Policy or as long as required for our legal or business purposes.

  • Additional data subject rights

In addition to the rights described above under “Your Rights”, you may in some cases ask us to delete your personal information. You can also object to certain personal information about you being processed and request that processing of your personal information be limited. Please note that the limitation or deletion of your personal information may mean we will be unable to provide the Services described above. You also have the right to receive your personal information in a machine-readable format and have such data transferred to another party responsible for data processing. If you disagree with how we process your personal information, you are also entitled to report this to the competent supervisory authorities in the European Union.

  1. Contacting us
    If you have any questions about this Privacy Policy, please contact our Privacy Officer at:

MediaValet Inc.
990 Homer Street, 5th Floor
Vancouver, BC V6B 2W7
Canada

Attention: Privacy Officer
Email: privacy@mediavalet.com
source: https://www.mediavalet.com/privacypolicy/