<img height="1" width="1" style="display:none" src="https://www.facebook.com/tr?id=1217706422396728&amp;ev=PageView&amp;noscript=1">

Website Privacy Notice


Last Update: June 27, 2023

Table of Contents


  1. How We Collect Personal Information
  2. How We Use Personal Information
  3. How We Disclose Personal Information
  4. Your Rights Over Your Personal Information
  5. Information Security and Storage
  6. International Transfers of Personal Information
  7. Links to Other Sites
  8. Changes to the Policy
  9. California Privacy Rights & Information
  10. Your Virginia & Other State Privacy Rights
  11. European Economic Area / United Kingdom / Switzerland Privacy Rights
  12. Contact Us

 

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
  • Any other website or application belonging to or affiliated with Vistar Media that links to this Privacy Policy (collectively, the “Sites”).

 

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.

This Privacy Notice applies to only information collected with respect to the Sites. It does not apply to our core services that help our clients identify where, and when, to place advertisements on mobile and digital-out-of-home media to reach their desired audiences. You can read more about how we collect, use, and share personal information in the course of providing our core services by reading our Services Privacy Policy.

“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. We do not, and will not attempt to, re-identify de-identified
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

We and our third party service providers use cookies, web beacons, and other tracking technologies (“Cookies”) to collect information about you automatically as you use the Sites. We collect the following categories of information automatically when you use the Sites:

    • 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.

We may use software on our Sites that collect data from your device in order to help us analyze how users navigate and use the Sites.  For example, it may record and report to us that you clicked on a particular link, opened a form, typed a question or similar actions taken with your mouse and keyboard.  We use such data solely for internal analytical purposes.

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.

 

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to some direct marketing activities, to our use of Cookies in the European Union, or to our processing sensitive personal information). If we ask for your consent to process your personal information, you may withdraw, where permitted by law, your consent contacting us using the details at the end of this Privacy Notice.

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 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:

  • Identifiers;
  • 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 Choices

There are many ways to opt out of receiving targeted advertising that our clients may facilitate
using our Platform or other technology. Different devices use different technologies and
identifiers, so users must separately opt out from each browser and device. Once you opt out of
targeted advertising, your personal information will no longer be processed for targeted
advertising on that device or browser.

Mobile Apps and Location Data

Your mobile device may give you the ability to opt out of the use of information regarding the
apps that you use for targeted advertising. You may opt out of the collection of location
information by specific apps or from your entire device at any time by changing your
preferences on your mobile device. For more information regarding your preferences and
options, please see the link found here http://www.networkadvertising.org/mobile-choice and in
the Cookies, Tracking, and Interest-Based Advertising section below.

  • Cookies, Tracking, and Interest-Based / Targeted Advertising

 

If you would like to stop or restrict the placement of cookies or flush any cookies that may
already be on your computer or device, please refer to and adjust your web browser
preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting
cookies or disabling future cookies, you may not be able to access certain areas or features of
the Sites or some of its functionality may be affected.

For clarity, cookie-based opt-outs must be performed on each device and browser that you wish
to have opted out. For example, if you have opted out on your device browser, that opt-out will
not be effective on your mobile device. Additionally, if you opt out on one of your devices, that
opt out may not be effective on all of your devices. You must separately opt out on each device.

Please note that cookie-based opt-outs are not effective on some mobile services. Users may
opt out of certain advertisements on mobile applications or reset advertising identifiers via their
device settings. To learn how to limit ad tracking or to reset the advertising identifier on your
iOS and Android device, click on the following links:

iOS - https://support.apple.com/en-us/HT202074

Android - https://support.google.com/ads/answer/2662922?hl=en

You may also download and set your preferences on the DAA’s App Choices mobile
application(s) provided by the Digital Advertising Alliance (DAA) available in Google Play or the
Apple App stores to opt-out of behavioral advertising from DAA members.

  • Do Not Track

 

Some browsers have a “do not track” (also known as DNT) feature that lets you tell websites
that you do not want to have your online activities tracked. Please note that, unless required by
law, we do not respond to or honor DNT signals or similar mechanisms transmitted by web
browsers. However, we treat Global Privacy Control signals as opt-out of sharing of personal
information for cross-context behavioral advertising requests under the California Consumer
Privacy Act/California Privacy Rights Act, and as opt-out of processing for targeted advertising
requests under the Virginia Consumer Data Protection Act.

 

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 1-833-202-5126 to leave us a
message, or send a letter to our Privacy Officer at 149 Fifth Avenue, Sixth 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.

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.

The rest of this section relates to our processing of personal information as a “business.”

These provisions apply only to California consumers and supplement this Notice. This California
Privacy Rights section describes your rights under the California Consumer Privacy Laws,
explains how you may exercise your rights, and provides an overview on the types of personal
information we collect.

California Consumer Privacy Laws provide you with the following rights:

  • Right to know. You have the right to know what categories and specific pieces of
    personal information we collect about you, the sources from which we collect personal
    information, our business or commercial purpose for the collection, use, and sharing of
    your personal information, and any categories of third parties to whom we sell or with
    whom we share your personal information.  

  • Right to data portability. You have the right to request a copy of personal information
    we have collected and maintained about you in the past 12 months. California Consumer
    Privacy Laws allow you to request your information from us up to twice during a twelve
    (12) month period.  We will provide our response in a readily usable format, which is
    usually electronic.

  • Right to delete. You have the right to request that we delete the personal information
    that we have collected from you and maintained, subject to certain exceptions. Please
    note that if you request deletion of your personal information, we may deny your request or may retain certain elements of your personal information if it is necessary for us or our
    service providers to:
    • Complete the transaction for which the personal information was collected,
      provide a good or service requested by you, or reasonably anticipated within the
      context of our ongoing business relationship with you, or otherwise perform a
      contract between our business and you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or
      illegal activity; or prosecute those responsible for that activity.
    • Debug to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise his or her
      right of free speech, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act pursuant to
      Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal
      Code.
    • Engage in public or peer-reviewed scientific, historical, or statistical research in
      the public interest that adheres to all other applicable ethics and privacy laws,
      when the deletion of the information is likely to render impossible or seriously
      impair the achievement of such research, if you have provided informed consent.
    • To enable solely internal uses that are reasonably aligned with your expectations
      based on your relationship with us.
    • Comply with a legal obligation.
    • Otherwise use the personal information, internally, in a lawful manner that is
      compatible with the context in which you provided the information.

  • Right to opt out of selling or sharing. At the time this Notice was last updated, we do
    “sell” and “share” (as defined in the CCPA) personal information.
    You have the right to opt out of the sale or sharing of your personal information, along
    with the right to later opt in to the sale of such information. If we sell or share any of your
    personal information, you may, at any time, tell us not to sell or share your personal
    information. You can make this request by clicking here. We will also treat Global
    Privacy Control (“GPC”) browser signals as opt-out of sale/share requests.

  • Right to correct. You have the right to request the correction of any personal
    information we maintain about you.

  • Right to nondiscrimination. You have the right not to receive discriminatory treatment
    by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we
    will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through
      granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a
      different level or quality of goods or services.

 

In the past twelve (12) months, we have not disclosed personal information to third parties for
our business purposes.

California residents have rights relating to their personal information, including the rights to
know and to deletion. Please contact us at Privacy@VistarMedia.com, or using our Opt-Out
form, or at 1-833-202-5126 to leave us a message, or send a letter to our Privacy Officer at 149
Fifth Avenue, Sixth Floor, New York NY 10010.

Except with respect to opt out requests, we will need to verify your identity and that the
information you requested relates to you before completing your rights request, such as by
asking you to provide additional materials that verify your name and/or location. We will make
every effort to respond to your request within forty-five (45) days from when you contacted us. If
you have a complex request, the California Consumer Privacy Laws allow us up to ninety (90)
days to respond. We will still contact you within forty-five (45) days from when you contacted us
to let you know we need more time to respond.

CALIFORNIA “SHINE THE LIGHT”

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the
right to request in writing from businesses with whom they have an established business
relationship: (a) a list of the categories of personal information, as defined under Shine the
Light, such as name, email address, and mailing address, and the type of services provided to
the customer that a business has disclosed to third parties (including affiliates that are separate
legal entities) during the immediately preceding calendar year for the third parties’ direct
marketing purposes; and (b) the names and addresses of all such third parties. To request the
above information, please contact us by email at  Privacy@VistarMedia.com. If you do not want
your personal information shared with any third party who may use such information for direct
marketing purposes, then you may opt out of such disclosures by sending an email to us at
Privacy@VistarMedia.com.

If you are submitting a request through an authorized agent, the authorized agent must provide
your signed permission alongside the request. We may also request that authorized agents
verify their identity, and we may ask you directly to confirm your identity and that you have
authorized the agent to submit the request on your behalf.

10. Your Virginia & Other State Privacy Rights8. 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 eugenie@vistarmedia.com, and our Data Protection Officer Fazim Bacchus can be contacted at fbacchus@vistarmedia.com.

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.

Virginia law provides Virginia residents with the rights listed below, subject to applicable law. To
the extent your home state has a similar law that Vistar is subject to, we will provide these same
rights to you. Virginia residents may exercise these rights as detailed below or by visiting the
Opt-Out form.

The categories of personal information we process, our purposes for processing your personal
data, the categories of personal data that we share with third parties and the categories of third
parties with whom we share it are detailed above in this Notice.

Certain rights that you may have concerning your personal data are set forth in this Notice. The
VCDPA provides you with the following additional rights:

  • Right to know. You have the right to know and see what personal data we have
    collected about you.

  • Right to data portability. You have the right to obtain a copy of your personal data that
    you previously provided to us in a portable and, when feasible, readily usable format,
    where the processing is carried out by automated means.

  • Right to delete. You have the right to request that we delete the personal data we have
    collected about you.

  • Right to opt out of selling or sharing. You have the right to opt out of the sale of your
    personal data and/or the processing of your personal data for purposes of (i) targeted
    advertising or (ii) profiling in furtherance of decisions that produce legal or similarly
    significant effects concerning you. As of the latest date of the Notice:
    • We do engage in profiling decision based on your personal information that
      produce legal or similarly significant effects concerning you.
    • If you wish to opt out of the processing of your personal information for any of the
      purposes set forth in this sub-section, please click HERE.

  • Right to correct. You have the right to request that we correct inaccurate personal data.

  • Right to nondiscrimination. You have the right not to receive discriminatory treatment
    by us for the exercise of your VCDPA privacy rights. Unless permitted by the VCDPA,
    we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through
      granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a
      different level or quality of goods or services.

 

Exercising Your Virginia Privacy Rights 

If you wish to opt out of the processing of your personal information for targeted advertising,
please click fill out the Opt-Out form.

To exercise any of your Virginia privacy rights, or if you have any questions about your privacy
rights, you may contact us by:

 

Verification of Your Identity. After submitting a request, we will take steps to verify your
identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In
order to verify your identity, we will request, at a minimum, that you provide your name, email
address, phone number, address, and relationship to us, so that we can seek to match this
information with the information existing in our systems. When providing us this information, you
represent and affirm that all information provided is true and accurate. If we are unable to verify
using reasonably commercial efforts that the consumer submitting the request is the same
individual about whom we have collected personal information, then we are not required to
comply with the request; we may contact you for more information reasonably necessary to
authenticate the request, but ultimately we may not be able to meet your request.

Only you may make a verifiable request related to your personal information. If you are making
a request as the parent or legal guardian of a known child regarding the processing of that
child’s personal information, we may ask you to submit reliable proof of your identity.

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you
contacted us. If you have a complex request, the VCDPA allows us up to ninety (90) days to
respond. We will still contact you within forty-five (45) days from when you contacted us to let
you know we need more time to respond and the reason for the extension.

Your Right to Appeal

If we decline to take action regarding a request that you have submitted, we will inform you of
our reason for declining to take action and provide instructions for how to appeal the decision. In
the event that we do not respond to a request that you make pursuant to one of the privacy
rights set forth in this Virginia Privacy Rights section, you have the right to appeal our refusal to
take action within a reasonable period of time after you receive our decision. Within 60 days of
our receipt of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If the
appeal is denied, we will also provide you with an online mechanism, if available, or other
method through which you may contact the Attorney General to submit a complaint

.Your Nevada Privacy Rights 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal
information to third parties who intend to license or sell that personal information. You can
exercise this right by contacting us using the Opt-Out form or email us at
Privacy@VistarMedia.com with the subject line “Nevada Do Not Sell Request” and providing us
with your name and the email address associated with your account.

 

11. EUROPEAN ECONOMIC AREA / UNITED KINGDOM / SWITZERLAND PRIVACY RIGHTS

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE
UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND
DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER
APPLICABLE LAW.

Legal Basis

We will only use your personal data, as that term is defined under the General Data Protection
Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into
    with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your
    interests and fundamental rights do not override those interests.
  • Where you have consented to a certain use of your personal data.
  • Where we need to comply with a legal or regulatory obligation.

 

To the extent permitted under applicable laws, we will also process, transfer, disclose, and
preserve personal data when we have a good faith belief that doing so is necessary.

Data Controller

Vistar is the data controller of all personal data collected through our Website. To contact us,
please see the section titled Contacting Us.

If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our
privacy practices, you have the right to make a complaint at any time to your local supervisory
authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a
complaint, please contact our privacy manager here: Privacy@VistarMedia.com.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with
you, and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide you with our
services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources

We may obtain personal data and other information about you public sources and through our
third-party partners who help us provide our products and services to you.
Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw
your consent at any time by contacting us at Privacy@VistarMedia.com.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the United States and
other countries, some of which have not been determined by the European Commission or the
UK to have an adequate level of data protection. Where we use certain vendors, we may use
specific contracts approved by the European Commission or the UK Secretary of State which
give personal data the same protection it has in Europe. For more information about how we
transfer your data, please contact us at Privacy@VistarMedia.com.

Use of your personal data for marketing purposes

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising:

  • Promotional offers from us: We may use your personal data to form a view on what we
    think you may want or need, or what may be of interest to you. This is how we decide
    which products, services and offers may be relevant for you (we call this marketing). You
    will receive marketing communications from us if you have requested information from
    us or used our services and, in each case, you have consented to our use of your
    personal data for marketing purposes.

 

Data Subject Rights

If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data
subject, you have the right to:

  • Request access to your personal data (commonly known as a "data subject access
    request"). This enables you to receive a copy of the personal data we hold about you
    and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to
    have any incomplete or inaccurate data we hold about you corrected, though we may
    need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove
    personal data where there is no good reason for us continuing to process it. You also
    have the right to ask us to delete or remove your personal data where you have
    successfully exercised your right to object to processing (see below), where we may
    have processed your information unlawfully, or where we are required to erase your
    personal data to comply with local law. Note, however, that we may not always be able
    to comply with your request of erasure for specific legal reasons which will be notified to
    you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest
    (or those of a third party) and there is something about your particular situation which
    makes you want to object to processing on this ground as you feel it impacts on your
    fundamental rights and freedoms. You also have the right to object where we are
    processing your personal data for direct marketing purposes. In some cases, we may
    demonstrate that we have compelling legitimate grounds to process your information
    which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to
    suspend the processing of your personal data in the following scenarios: (a) if you want
    us to establish the data&#39;s accuracy; (b) where our use of the data is unlawful but you do
    not want us to erase it; (c) where you need us to hold the data even if we no longer
    require it as you need it to establish, exercise, or defend legal claims; or (d) you have
    objected to our use of your data but we need to verify whether we have overriding
    legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to
    you, or a third party you have chosen, your personal data in a structured, commonly
    used, machine-readable format. Note that this right only applies to automated
    information which you initially provided consent for us to use or where we used the
    information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal
    data. However, this will not affect the lawfulness of any processing carried out before
    you withdraw your consent. If you withdraw your consent, we may not be able to provide
    certain products or services to you. We will advise you if this is the case at the time you
    withdraw your consent.

 

To exercise your rights under the GDPR, please contact us at Privacy@VistarMedia.com.
Please note that in order for you to assert these rights, we may need to verify your identity to
confirm your right to access your personal data. This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. In order to verify your
identity, we may need to gather more personal data from you than we currently have.

 

12. Contact Us

Vistar Media, Inc. is the controller responsible for the personal information we collect and
process. Our Data Protection Officer Fazim Bacchus can be contacted at
fbacchus@vistarmedia.com.

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.