As the Internet and the World Wide Web accelerate the exchange of information between businesses and their clients, privacy and the safeguarding of information become increasingly important concerns. On our web site at thePlatform.com and within our Media Publishing System console, Community Manager, Support, and Technical Resource Center (“Service Portals”) , we occasionally ask you to give us information that helps us learn your requirements so that we can refine both our web site and our product offerings to better match your specific needs. Because we know how important it is to handle any information about you responsibly, we follow a policy that protects your privacy and makes sure that any information you trust us with is used exclusively to help us form a business relationship with you that benefits both your company and thePlatform for Media, Inc. (“thePlatform,” “us,” “we,” or “our”) – a wholly owned subsidiary of Comcast Corp.
thePlatform complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland respectively. Information regarding both the E.U. and Swiss Safe Harbor Frameworks can be found at : http://export.gov/safeharbor.
Please note that we only collect information from users in the European Union and Switzerland if our online console for media publishing is configured by our customer to do so or otherwise at our customer’s request.
INFORMATION COLLECTION AND USE ON OUR WEB SITE
When you request information from us, we may ask you to fill out a form soliciting information about you, your company, or your business. We might ask for contact information, such as your name, telephone number, address, e-mail address, and we may request that you create a username and password to log into the site. We might also ask you to tell us what your job function is or what digital media management solutions your company uses or plans to use. In most cases, the information is required, and you can’t receive the information if you don’t fill out the form.
We use the information we collect to build strong business relationships with our customers. We want your business, so we want our sales team to contact you. But when they do, we want them to know your needs and business requirements so they can offer you solutions that help your business succeed. We also use your contact information to send you information that we hope will help you make sound purchasing decisions – white papers discussing industry trends; customer newsletters; invitations to events such as seminars, Webcasts, and user conferences; and product announcements and upgrades. In addition, we use the information we collect for business purposes, including without limitation: (i) managing your on-line experiences (including verifying your authority to enter thePlatform’s web site or Service Portals); (ii) delivering requested services and information to you; and (iii) for business-related purposes permitted and/or required under applicable law or regulation.
Our web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
From time to time we may post customer testimonials/comments/reviews on our web site which may contain personally identifiable information. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial.
Access to Information Collected on Web Site
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, or request deletion contacting us at safeharborcontact@theplatform or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within thirty (30) days.
COLLECTION/USE OF PERSONAL DATA RECEIVED FROM CUSTOMERS WITHIN SERVICE PORTALS
With regard to personal information that we receive regarding our Customers’ end-users while on our Service Portals, we collect such information only where we process it on behalf of our customers. We do not collect such information unless authorized by our Customers, nor do we disclose this information except as directed by our Customers. Our Customers maintain their own privacy policies applicable to the use and disclosure of end-user information.
We use Customer Personal Data for business purposes, including without limitation: (1) delivering requested goods, services, or information to you; or (2) for business-related purposes permitted and/or required under applicable local law and regulation.
Your Choices About How We Handle Your Personal Data
We collect information for our Customers, if you are an end-user of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly. If you are a Customer and would like to update your account please contact us at firstname.lastname@example.org.
Service Provider, Sub-Processors/Onward Transfer
thePlatform may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Customers.
If we learn that one of our sub-processors/service providers is using or disclosing Personal Data in a manner contrary to this Policy, we will take necessary steps to prevent or stop the use or disclosure.
We do not request and we do not believe we maintain sensitive data about our Customers. If you provide us with any sensitive data such as financial information or health information about your end-users, you are responsible for giving any required notice and obtaining any required consent for the collection, use, and disclosure of such sensitive data.
Right to Access, Change, or Delete Personal Data
Upon reasonable request and to the extent the request does not compromise the protections set forth in this Policy, we allow Data Subjects reasonable access to their Personal Data [including any Sensitive Data] that we may maintain. Individuals have the right to receive confirmation from us about the data relating to them that we store in our files and may request that we correct, amend, or delete that information when it is inaccurate. Customers should direct any such request to the VP Global Operations at the address listed below.
We will respond to all access requests to view, modify, or delete Personal Data within thirty (30) days.
Customers are responsible for the accuracy of the data they provide to us. We will use reasonable efforts to maintain the accuracy and integrity of any Personal Data we receive and update it as appropriate.
We do not, as a matter of business practices, maintain Personal Data longer than necessary for the purposes stated, unless otherwise agreed to by the Customer.
GENERAL PRIVACY PRACTICES: All Users
Disclosure of Personal Information
Note that we may provide aggregated data regarding usage of our site and other non-personally identifying information to third parties. The statistics we compile regarding usage of the web site are provided only in aggregate form, contain no personal information and cannot be used to discern such information.
We use other third parties such as our hosting provider and marketing partners to provide services on our behalf. Our service providers will only use the information shared with them to provide the services we have contracted them for. Our service providers may not use your information for their own marketing purposes.
In the event thePlatform goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for thirty (30) days following the transaction of any such change in ownership or control of your personal information.
We use both session ID cookies and/or persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
Our systems are not set up to track, collect or distribute personal information about you automatically or without your knowledge. Our systems do recognize the home server of users of the web site, but not their email addresses. For example, our computer servers can tell which Internet Service Provider visitors to our web sites use, and the IP addresses associated with users’ computers, but not the names, addresses or other information that would allow us to identify particular users of our sites. The non-personal information collected by our servers is used for internal purposes only (such as to ensure the smooth functioning of our web sites and efficient delivery of content on the sites, for example knowledge of the web browser used allows content to be displayed in the manner best suited for that web browser) by thePlatform’s technical support staff.
In addition, our third party tracking utility partners and thePlatform’s servers track information about the visits to our web sites using log files. For example, we compile statistics that show the daily number of visitors to our sites, the daily requests we receive for particular files on our sites and what countries those requests come from. These aggregated statistics are used internally to provide better services to our web site users. These log files are not tied to personally identifiable information.
Links to Third Party Sites
California Privacy Rights
California law permits its residents to request and receive information about a business’ disclosure of certain categories of personal information to other companies for their use in direct marketing. If you are a California resident and a user of this web site, you can request a copy of this information from us by sending an email to email@example.com or a letter to us at 1000 Second Ave Suite 1000, Seattle, WA, 98104. Please include your name and email address in email requests, and your name and physical address in mail request.
Our web site and services are not intended for anyone under the age of 13. We do not knowingly collect personal information from anyone under the age of 13. If we find out we have collected personal information from anyone under the age of 13, we will delete this information immediately.
Chief Legal Counsel
1000 Second Avenue
Seattle WA 98104
Capitalized terms in this Policy have the following meanings:
“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, psychological, mental, economic, cultural, or social identity. For purposes of this Policy, “Data Subject” means our Customers.
“European Affiliate” means our affiliate(s) located in Switzerland, the EU, or EEA.
“Customer” means any individual that is a prospective, current, or past Customer of thePlatform who is also a resident of Switzerland, the EU, or EEA.
“Personal Data” means data that personally identifies a Data Subject or that may be used to personally identify a Data Subject (such as an identification number that identifies a Data Subject). Personal Data includes data such as an individual’s name, country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID and password. Personal Data does not include data that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data.