Website Privacy Notice
Last Update: July 1, 2020
- How We Collect Personal Information
- How We Use Personal Information
- How We Disclose Personal Information
- Your Rights Over Your Personal Information
- Information Security and Storage
- International Transfers of Personal Information
- Links to Other Sites
- Contact Us
- Changes to the Policy
- California Privacy Rights & Information
This Website Privacy Notice (“Privacy Notice”) describes how Vistar Media, Inc. (“Vistar,” “we,” “our,” or “us”), processes personal information in relation to:
- Our website, vistarmedia.com (the “Website”),
- Our platforms that allow our clients to plan and execute campaigns on our core services (“Platforms”), and
This Privacy Notice describes how we collect, use, share, and secure the personal information we collect via the Sites and describes your choices regarding use, access, correction, and deletion of such personal information.
“Personal information” is information that identifies, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, with a natural person and, where required by law, a household. This Privacy Notice does not apply to anonymous, de-identified, or aggregate personal information.
1. How We Collect Personal Information
We collect personal information from you when you use the Sites, and the information we collect depends on the way in which you interact with the Sites. We may collect information directly from you, such as when you create an account on our Platform, and we may automatically collect information by using cookies or other technologies. We may also supplement the information we collect from you with information from other commercially-available sources (where permitted by law). We describe the types of information we collect and the sources in more detail below.
We may collect some personal information to satisfy our legal obligations or as necessary to enter into and perform our contractual relationship with you. Failure to provide such information may prevent or delay us from providing you the Sites.
1.1.Information You Provide
We collect the following categories of personal information directly from you when you use the Sites:
- Identifiers, such as your name, address, country of residence, phone number, or email address;
- Professional Information such as your job title or company;
- Your preferences, such as how often you wish to receive marketing or other communications
1.2.Information We Collect Automatically
- Identifiers, such as your IP (Internet Protocol) address, your browser type, your operating system, or domain name;
- Internet or other electronic network activity information, such as the dates and times you used the Sites and the way in which you accessed them;
We may combine this information with other information that we collect about you.
1.3.Information We Collect From Other Sources
We may collect information about you from third party sources, including suppliers that help us prevent fraud, marketing agencies, and analytics providers. The categories of personal information we collect from these sources include:
- Identifiers, such as your name or date of birth;
- Geolocation information;
- Protected Characteristics;
2. How We Use Personal Information
We use your personal information primarily to provide the Sites and to respond to your inquiries. We may also use your personal information to:
- Communicate with you, including responding to your inquiries or comments, to request feedback regarding our offerings, and to provide information about your account and campaigns.
- Provide, improve, and personalize the Sites and our offerings, including by better understanding our customers, tailoring our Sites and offerings to your interests, and creating new products or services.
- Send you marketing communications and advertisements, such as newsletters and updates about our latest events and products, consistent with your marketing preference. Where permitted by law, we may also send you information about products or services that we believe might be of interest to you, including products or services offered by third parties
- Evaluate the success of our advertising campaigns, improve our products and services, and analyze use of the Sites by employing techniques such as advance statistical analytics.
- Comply with the legal and regulatory obligations to which we are subject and cooperate with regulators and law enforcement bodies.
- Protect our rights, interests, and safety and the rights, interests, and safety of you and third parties.
Certain jurisdictions, including the European Union, have laws that require us to have a “legal basis” to process your personal information. Where required by applicable law, we rely on one of the following legal bases to justify our processing of your personal information:
- to fulfill our contractual obligations to you, for example to provide access to Platforms and other Sites that you request and to ensure that invoices are delivered or paid correctly. Failure to provide personal information necessary to perform a contract may prevent or delay the fulfillment of our contractual obligations;
- to comply with our legal obligations, for example to respond to legally binding requests from regulators, law enforcement authorities, or other government authorities;
- to meet our legitimate interests, for example to understand how you use the Sites and to enable us to derive knowledge that enables us to develop new offerings. When we process personal information to meet our legitimate interests, we put in place safeguards to protect your privacy and to determine that our legitimate interests are not overridden by your interests or fundamental rights and freedoms; and
- to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims, or other violations of law.
3. How We Disclose Personal Information
We share your personal information for our business purposes with the following categories of persons and in the following circumstances:
- Third Party Service providers. We may share your personal information with entities that act on our behalf as our agents, suppliers, or providers to more efficiently provide the Sites. These entities may also collect your personal information on our behalf. Service providers may provide services such as marketing support, technical assistance, data hosting, payment processing, customer service support, and data analytics.
- Legal Compliance and Protection of Our Rights: We may share information with regulators, law enforcement, government authorities, and other third parties where we believe it necessary to comply with a legal or regulatory obligation, including a court order, subpoena, and regulatory request. We may also disclose information when we believe in good faith that such disclosure will help us protect our rights, enforce our Terms of Service, protect our safety and security or that of you or any third party, or detect, prevent, or respond to fraud or intellectual property infringement.
- Transfer of Business Assets. We may share your personal information with any third party involved in the consideration, negotiation, or completion of a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Vistar Media or as part of a corporate reorganization or stock sale or other change in corporate control.
- Additional Sharing. We may share your information with our attorneys, banks, auditors, brokers, and other professional service providers and advisors in connection with the purposes above.
We may share the following categories of your personal information with the entities above:
- Professional Information;
- Commercial Information;
- Geolocation information;
- Protected Characteristics;
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International Transfers of Personal Information” below for more information.
4. Your Rights Over Your Personal Information
Subject to local law, you may have certain rights regarding your personal information. These rights may include, depending on the circumstances, the rights to access your personal information, rectify the information we hold about you, erase your personal information, restrict our use of your personal information, object to our use of your personal information, receive your personal information in a usable electronic format and transmit it to a third party (right to data portability), receive additional information regarding the sources from which we collect information, the purposes for which we collect and share personal information, the information of yours we hold, and the categories of parties with whom we share your information, lodge a complaint with your local data protection authority, and withdraw any consent you have given. If you would like to discuss or exercise such rights, please contact us at Privacy@VistarMedia.com, or using our Opt-Out form, or at 1-866-I-OPT-OUT (1-866-467-8688) and entering service code 1002# to leave us a message, or send a letter to our Privacy Officer at 156 Fifth Avenue, Fourth Floor, New York NY 10010.
California residents should consult the “Your California Privacy Rights” section below for more information about their rights and additional disclosures. You may exercise your rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate as permitted by applicable law.
If you are a registered user of our Platforms, you can access your personal account information and make changes through your account.
5. Information Security And Storage
We have put in place safeguards to help prevent unauthorized access to and maintain the security of your personal information. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your personal information.
We retain your personal information for as long as we have a relationship with you and for a period after the relationship has ended. When determining how long to keep your personal information, we consider how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including regulatory obligations. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
6. International Transfers Of Personal Information
We may transfer, process, and store your personal information outside of your home country, including in the United States and Canada, which may not have the same level of data protection as your home country. If you are resident in the European Economic Area (“EEA”) this may include the transfer of your personal information from within the EEA to a country outside of the EEA.
Where required, we have implemented appropriate safeguards for such transfers, such as implementing standard contractual clauses approved by the European Commission. For more information on the safeguards we use, please contact Privacy@VistarMedia.com.
7. Links To Other Sites
Our site includes links to other websites whose privacy practices may differ from our practices. If you submit personal information to any of those sites, your information is governed by their privacy statements. We are not responsible for the privacy practices or the content of any sites to which the Sites link. We encourage you to carefully read the privacy statement of any website you visit.
8. Contact Us
Vistar Media, Inc. is the controller responsible for the personal information we collect and process. Our representative is Eugenie Chen can be contacted at email@example.com, and our Data Protection Officer Fazim Bacchus can be contacted at firstname.lastname@example.org.
If you have questions or concerns regarding the way in which we used your personal information, please contact us at Privacy@VistarMedia.com. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority.
9. Changes To The Policy
We may modify or update this Privacy Notice from time to time. Any modifications or updates that we post will be effective immediately except where prohibited by law or as we otherwise indicate. We will notify you of changes to this Privacy Notice by updating the date at the top of this Privacy Notice or by other means, such as by e-mail or notice within the Sites, where required by applicable laws.
10. Your California Privacy Rights & Information
We do not share or sell personal information in relation to content accessed on our website.