TABLE OF CONTENTS
- Information We Collect
- How We Use and Share The Information Collected
- Legal Grounds for Using (Processing) Your Information
- Online Analytics and Advertising
- Data Subject Rights & Your Choices
- Retention of Your Information
- Cookies and Other Tracking Technologies
- Links to Third Party Sites
- Special Note For Parents
- Transfer Information to the United States
- Disputes; No Rights of Third Parties
- Contact Us: Data Privacy Officer
Information We Collect.
Information You Provide To Us.
We collect the information you provide when you enter a sweepstakes or contest, complete a survey, participate in a reader panel, register for a part of our Websites, register for a summit or event, make a purchase, participate in our social networking features, request back issues of our Publications, subscribe to our Publications, subscribe to newsletters, promotional correspondence, or other electronic services, or send us an email or feedback. If you select to post material to any blogs, forums, participate in our social networking features or other community boards that may be offered on our Websites, then such materials will be collected and some information, including your posted pseudonym, may be publicly available for others to view. The information you may provide includes:
- Registration or Subscription Information, Communications and Requests from You, and Your Submissions. When you engage in activities on the Websites such as those above, you may be asked to provide information such as your e-mail address, name, phone number, shipping address, and billing information, and we (or third party service providers on our behalf) will collect such information as well as any other content you provide us in engaging in any of the above activities. Information such as your age, date of birth, gender, hobbies or interests may also be requested.
- Billing and Credit Card Information. To enable payment for subscriptions to our Publications, our vendors collect and store billing and credit card information. This information may be shared with us, and will only be shared with third parties who perform tasks required to complete the purchase transaction such as fulfilling orders and processing credit cards. We also use third party platforms to process payments for some of our events and summits, and these third party platforms may collect and store billing and credit card information. The processing of your billing and credit card information by these third party platforms are subject to their privacy policies. Some of our Websites may accept billing and credit card information by phone or mail to process payments for advertisements and listings. This information will only be used by us to process the authorized payments.
Information Automatically Collected As You Access and Use the Websites.
- Usage Information. In addition to any information that you choose to submit to us, to provide you with services and content that are more customized to your interests, WINNERZCIRCLE.COM and our third-party service providers and advertisers may use a variety of technologies (including cookies, Flash cookies, web beacons and embedded scripts) (“Cookies”) that automatically or passively collect information when you visit or interact with the Websites (the “Usage Information”). This Usage Information may include, without limitation, your IP address, the URL that referred you to our Websites and all of the areas within our Websites that you visit, the web sites you visit after this web site; the ads you see; the ads you click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this web site or a referral site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers. Your IP address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your library. We use your IP address for a variety of purpose, including to help diagnose problems with our servers, gather broad demographic information, and administer our Websites. We may also link this information with your other information when we feel that it is necessary to enforce compliance with our subscription or usage rules and policies or terms of service or to protect our Websites, customers or others.
- Usage Information gathered from your use of the Websites may be combined with information from third party sources to identify your location by state and region. For more information, see “Cookies and Other Tracking Technologies” below. Geolocation Information. With your consent, certain mobile Websites or a third party such as an advertiser may collect and use your geolocation to provide you with information about goods and services within your geographic location or implement other functionality in the Website, such as to serve targeted advertising. In addition, when you have geolocation software running on your mobile phone, computer or other device, we may collect that information as controlled by your privacy settings on those devices. By using such service, you hereby consent to our collection, use and disclosure of your geolocation information as described.
- Information You Provide About A Third Party. At some Websites and through certain promotions, you can submit information about other people such as a person’s name and mailing address to send a gift. This information is used to facilitate the communication or provide the service and may otherwise be used as set forth herein. If that person becomes a subscriber to one of more of our Publications, or becomes an attendee or sponsor or speaker at one of more of our events, his/her information will be treated in the same manner as all others in that category. Please be aware that when you use any send-to-a-friend functionality on our Websites, your email address may be included in the communication sent to your friend.
How We Use and Share the Information Collected.
- Provide, Manage and Improve our Websites. COM uses information we collect from you in part to provide you with the goods and service you have requested (e.g., to sign up for an event, request promotional materials directly from a third party partner), to respond to your inquiries, to administer the Websites and for other lawful business purposes.
- Advertising and Analytics. We use the information in connection with advertising and to serve other content, as described below. We also use the information we collect and obtain about you to measure and improve our Websites, to customize certain features of the Websites, to deliver relevant content and to provide you with an enhanced experience based on the type of device you are using.
- Transactional Communications. We use the information provide transactional or service communications about the Websites, such as to notify you when you have won one of our contests or sweepstakes or other promotions (a “Promotion”), when we make changes to subscriber agreements, to fulfill a request for you for an email newsletter, or to contact you about your account. If you wish to unsubscribe from our email newsletters, please follow the unsubscribe/opt-out instructions at the bottom of the newsletter.
- Reader Surveys. We may collect information from you in connection with voluntary surveys about your readership of our Publications, your household/personal characteristics and your purchase behavior. The information you provide in any audience marketing surveys will only be shared in the aggregate with advertisers and partners unless we notify you otherwise at the time of collection. Any other survey results may be shared with advertiser and partners, at our discretion, unless we notify you otherwise at the time of collection.
- Editorial Use. In addition, we may use information you provide us through emails, blogs, forums, in response to polls, or through any other user generated submission for editorial purposes, and may use your name and any stories you provide us in articles published in our Publications. If you provide us with personal anecdotes, they may be attributed to you. WINNERZCIRCLE.COM can edit, rewrite, use, and reuse the content, including your name, likeness, photograph, and biographical information you provide, with or without attribution, including publication in the Publications, and in trade media, and advertising. You hereby consent to this.
- Marketing. Subject to applicable law, we may combine and use any and all information we collect on you either online or otherwise, including from third parties, for marketing purposes, including sending you promotional emails regarding special offers about our products and services or on behalf of third party marketing partners who we think can offer services and products of interest to you. Unless we expressly notify you otherwise at the time of collection, we also may disclose information that we receive from you and from third party sources to third parties whose practices are not covered by this privacy statement (e.g. other marketers, magazine publishers, retailers, participatory databases and non-profit organizations) that want to market products or services to you. This includes licensing information about your interests and activities, and marketing segments created with such data, which we may share with third parties for their marketing purposes.
- Promotions. By agreeing to participate in a Promotion, you are agreeing to the official rules that govern that Promotion.
- Anonymous Information. We may create aggregated or anonymized information about you and other users of the Websites by excluding information (such as your name) that relate to an identifiable individual (“Anonymous Information”). We may use this Anonymous Information for any purpose permitted under the law and disclose Anonymous Information to third parties in our sole discretion.
- Third Party Contests and Promotions. In some cases you may have entered a contest or sweepstakes sponsored by a third party, in which case the information you provide via the contest or sweepstakes may be shared by us with that third party for their use in their discretion, including direct marketing. Some of our contests and sweepstakes will ask you at the time of entry whether you would like to have your personal information shared with the sponsor, in which case we will honor your selection. Other contests will not give you that option and in that event, if you do not want your information to be shared, you should not enter the contest. The privacy policies of such third party companies apply to their use and disclosure of your information that we collect and disclose to such third party companies.
Legal Grounds for Using (Processing) Your Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it.
We collect information from you:
- where we need it to perform our contract with you (i.e. ourTerms of Service),
- Where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights)( such as personalizing our services and marketing for example), or
- If we otherwise have your consent. l If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.
Online Analytics and Advertising
Delivery of Advertising and Other Content. In addition to ads and content that we serve you directly, WINNERZCIRCLE.COM may use third party advertising companies and marketing services to serve ads and other content when you visit the Websites and elsewhere on the internet and in other media. We also use analytics services supported by third party companies to perform analytics and track trends. We work with other third parties to provide certain functionalities on the Websites and to improve the effectiveness of the Websites and its content. Those third party companies may use Tracking Technologies to collect and store Usage Information about you and may combine this information with information they collect from other sources. If you access the Websites through a mobile device or app, we may also share your information with mobile carriers, operating systems and platforms.
To provide ads on the Websites, we use a variety of third-party advertising service providers, including networks, data exchanges, ad servers, analytics providers and others. The list of third-party providers is found in the Section below entitled “Third Party Cookies”. This list may be updated from time to time. These third parties may use technology to send, directly to your Device, the advertisements and links that appear on the Websites. They may automatically receive your IP address, web browser, operating system, and time and location information, geo device type and device ID when this happens. The third party service providers, as well as the advertisers themselves, may collect and use information about your visits over time and across the Websites and other third party websites, as well as information received from other sources, in order to serve more targeted advertising to you on the Websites. Third parties may also use information gathered from your usage of the Websites to serve targeted advertisements to you on third-party websites and applications. Google is one of the companies that we use to serve advertising and perform analytics on some of the Websites. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to help implement the above uses of your information.
We also use Google Analytics along with audience data (such as age, gender and interests of users) to help understand users’ visits to the Websites and to optimize the content that we serve to users.
We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.
Your Choices about Ads and Analytics. To learn more about how to manage your preferences regarding our cookie-based advertising, please see the“Cookie Management” section in our Cookie Notice below.
In addition, if you do not want to receive tailored in application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt-out by adjusting the ad tracking settings on your mobile device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.”Like the opt-out tools mentioned above for web, these mobile optout tools are provided by third parties, and we do not control or operate these tools.
Please note that you may still receive advertisements from third parties within the Websites even if you opt out of tailored advertising but they will not be based on your activity across unrelated websites or apps.
Do Not Track. WINNERZCIRCLE.COM does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on our Websites. For more information, go to http://www.networkadvertising.org or http://www.aboutads.info.
Data Subject Rights & Your Choices
Subject to certain local laws, you have certain rights with respect to your information as further described in this section.
(a) Your Legal Rights. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time. Your local laws may permit you to request that we:
- provide access to and/or a copy of certain information we have about you;
- prevent the processing of your information for direct marketing purposes;
- update information which is out of date or incorrect;
- delete certain information which we have about you;
- restrict the way that we process and disclose certain of your information;
- transfer your information to a third party provider of services; and
- revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
(c) SMS Communications. You may opt-out of SMS messages from us by following the instructions provided in the message or by texting back STOP to the number we send the text from for that particular SMS message. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
(d) Geolocation. If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings for the relevant application or the “settings” page for the relevant game.
(e) California Users: Your California Privacy Rights. Under California Civil Code sections 1798.83- 1798.84, California residents may annually request information regarding what categories of personal information (as defined by such law) WINNERZCIRCLE.COM shares with third parties for those third parties’ direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit a request to the following email address: [email protected], 10880 Wilshire Blvd., Los Angeles, CA 90024. In your request, please specify that you want a “WINNERZCIRCLE.COM California Privacy Rights Notice.” Please allow at least 30 days for a response.
(f) Subscriber Preferences. Subscribers to our Publications may change their subscription-related mail and email preferences at any time as follows.
Retention of Your Information. We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws.
Cookies and Other Tracking Technologies. We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively,“Cookies”) on the Websites. This section (“Cookie Notice”) explains what these technologies are and why we use them, as well as your rights to control our use of them. We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.
What are Cookies?
Cookies are text files that contain a certain amount of information and are downloaded to your computer or mobile device when you visit a website. They are useful because they allow websites to recognize a user’s device. They are then returned to the original website on each subsequent visitor to any other website that recognizes them. For more information on cookies, go to http://www.allaboutcookies.org. The term “Cookie” is used in this Notice in the broad sense to include all similar techniques and technology, including web beacons and log files. For more information on these additional tools, see our glossary below.
Types of Information We Collect
Cookies help us to understand Website usage and to improve the content and offerings on our Websites and in other media. Examples of the types of information that we collect through Cookies include:The number of users visiting Websites, the number of times a Website was viewed, the pages viewed, the clicks made on the Websites and the total duration of navigation on the Websites; The name of the page that referred you to the Website; Whether this is your first time visiting the Website; Your viewing preferences (e.g. layout, sizing preferences, language etc.) Your username, your password, the type of browser used and your IP address, so that we can identify you during your next visits.
- To control the display of ads;
- To track usage patterns on the Websites;
- To deliver editorial content;
- To record requests for subscriptions;
- To implement our affiliate marketing program; and
- To personalize information.
Types of Cookies We Use on Our Websites
We use first party and third party Cookies for several reasons. Some Cookies are required for technical reasons in order for our Site to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies also enable us to track and target the interests of our users and to enhance the experience on our Websites. Third parties also serve Cookies through our Websites for advertising, analytics and other purposes. The specific types of first and third party Cookies served through our Websites and the functions they perform are described in more detail below.
These cookies are created by WINNERZCIRCLE.COM. They allow you to browse our Websites and use their features.
Essential Cookies: These cookies are strictly necessary to allow you to move around the Websites and use their features, such as accessing your subscriptions. Without these cookies, we cannot enable appropriate content based on the type of device you are using. Therefore, these cookies cannot be disabled.
Functional Cookies: These cookies allow us to remember choices you make on our websites (such as your preferred language or the region you are in). To refuse these Cookies, please follow the instructions below under the section Cookie Management. Note that by disabling functional cookies, you may not be able to use some of our features or those features may not function properly.
Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Websites, such as the links you click on. The code is temporarily downloaded onto your computer or another device, is active only while you are connected to the Websites, and is deactivated or deleted thereafter.
Advertising Cookies: These Cookies, defined exclusively by third parties, collect several types of data about your browsing habits, as well as your preferences for products and services. This information allows WINNERZCIRCLE.COM to serve you relevant advertisements on our Websites. To refuse these cookies, please follow the instructions below under the section Cookie Management. Some advertisements may also contain an icon that you may click on to find out more about how to manage your advertising preferences.
Third-Party Functional Cookies: These Cookies are defined by third parties who support our Websites and allow you to use useful services and features. To refuse these cookies, please follow the instructions below under the section Cookie Management. As of the Effective Date above, the third party partners include the following. This list may be updated from time to time:
Integral Ad Science
Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags“) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management.
HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Websites. This information may be retrieved by us to help us manage our Websites, such as by giving us information about how our Websites are being used by our visitors, how they can be improved, and to customize them for our users.
Types of Cookies We Serve on Third-Party Websites Duration of storage of cookies on your device
We use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which stay on your computer until you delete them).
Analytics To learn about Google Analytics currently available opt-outs for the Web, please visit https://support.google.com/analytics/answer/181881?hl=en.
Disabling Advertising Cookies Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages after you opt-out, but they will not be customized to you based on your use of the Websites and/or third party websites. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept these cookies, you can go to http://www.networkadvertising.org. If you would like to learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising and to know your choices about not having information used in this manner, you can go to http://www.aboutads.info. The collection of information via certain ads served to users in Canada may be managed by visiting youradchoices.ca. Please note that the opt out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.
Using Browser Settings You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ Websites. The following links provide information on how to modify the cookies settings on some popular browsers: Apple Safari http://support.apple.com/kb/PH5042 Google Chrome https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies Microsoft Internet Explorer http://windows.microsoft.com/en-US/windows7/How-to-managecookies-in-Internet-Explorer-9 Mozilla Firefox http://support.mozilla.org/en-US/kb/Cookies
Managing Cookie Preferences on Our Websites To manage your cookie preferences for our websites, including advertising cookies served by advertisers that participate in the IAB Europe GDPR Transparency & Consent Framework Global Vendor List, please click on the “Privacy Preferences” link in the footer of the relevant Website.
We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while WINNERZCIRCLE.COM uses reasonable efforts to protect your information, WINNERZCIRCLE.COM cannot guarantee its absolute security, and your use of the Websites indicates your agreement to assume this risk.
Special Note For Parents.
The Websites are for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.
Transfer Information to the United States.
The Websites are operated in the United States of America (USA) and are intended for users located in the USA. If you are located outside of the USA, please note that the information you provide to us will be transferred to and processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country.
Disputes; No Rights of Third Parties.
Contact Us: Data Privacy Officer.