PRIVACY POLICY
JM-Higgins Media, LLC ("JM-HM"), respects your concerns about privacy. This Online Privacy Notice describes how JM-HM processes the Personal Data:
that we collect on http://www.justinmhiggins.com/ (the "Site"); and,
through other data collection points or notices that reference this Online Privacy Notice.
JM-HM provides information on the types of Personal Data JM-HM collects, how JM-HM uses the information, with whom JM-HM may share it and the choices available to you regarding JM-HM’s use of the information. JM-HM also describes the measures JM-HM takes to protect the security of the information and how you can contact JM-HM about its privacy practices. "Personal Data" is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information.
INFORMATION OBTAINED BY JM-HM
Information that you give JM-HM
The types of information JM-HM collects concerning individuals includes:
business and personal contact information (such as name, postal and email addresses, and telephone number); and,
other information you provide to JM-HM (such as information provided by registering for email alerts or filling in forms).
Other information:
In connection with electronic interactions you have with JM-HM or its service providers (including by email, phone or other forms of electronic communication), JM-HM may record and monitor details of those interactions, including their content, to the extent permitted or required by applicable law.
JM-HM may also collect some information from other sources, including:
if JM-HM has a business relationship with the organization that you represent, your colleagues or other business contacts may give JM-HM information about you such as your contact details or details of your role in the relationship; and,
information from third party data providers or publicly available sources for background checking and similar purposes, and to protect JM-HM’s business and comply with JM-HM’s legal and regulatory obligations.
INFORMATION OBTAINED BY JM-HM BY AUTOMATED MEANS
JM-HM may use third-party web analytics services on the Site, such as those of Google Analytics. These service providers help JM-HM analyse how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plugins and widgets on the Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
HOW JM-HM USES THE INFORMATION JM-HM OBTAINS
JM-HM may use, disclose or otherwise handle the information described in this Online Privacy Notice for the following purposes to:
operate, evaluate, develop, promote, and improve JM-HM’s business (including developing new products, content, events and services; enhancing, improving and analysing JM-HM’s products, content, events and services; managing JM-HM’s communications; and performing accounting, auditing and other internal functions);
create and manage your account;
comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
protect against, identify and prevent fraud, breach of confidence, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
in some cases, in order to operate, administer and improve the user's experience of the Site;
provide JM-HM’s products, content, events and services to you, such as email alerts;
send you (or produce) promotional materials, newsletters and other communications (such as e-mails), including in visual and audio form (such as videos, podcasts and online seminars);
communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
respond to your inquiries;
verify your information; and
perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information).
JM-HM may also use the information in other ways for which JM-HM may provide specific notice at the time of collection.
JM-HM will only process your Personal Data as necessary so that JM-HM can pursue the purposes described above. Where JM-HM processes your Personal Data for its legitimate interests as a business or those of a third party, we do so only where JM-HM has concluded that its processing does not prejudice you or your privacy in a way that would override JM-HM’s legitimate interest in pursuing those purposes.
When JM-HM collects Personal Data from you, unless indicated otherwise, you should assume that, if JM-HM asks you for information, JM-HM needs it for its business or compliance purposes. In limited circumstances, JM-HM may be required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.
If you are a former contractor, worker or similar of JM-HM, JM-HM will continue to process your Personal Data for a reasonable period following the end of your engagement for JM-HM’s legitimate business and / or its legal compliance purposes and / or for the establishment or defense of a legal claim. Further, in some instances, JM-HM may process your data to perform its obligations under the contract between JM-HM (e.g. to pay you your final payment after your termination date). JM-HM only carries out such processing where it has concluded that its processing does not prejudice you or your privacy in a way that would override JM-HM’s legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).
ONLINE TRACKING AND INTEREST-BASED ADVERTISING
JM-HM and third parties acting on its behalf (such as Facebook, Twitter and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, JM-HM will obtain your consent for the processing of your Personal Data for direct marketing purposes.
You may see JM-HM ads on other websites or mobile apps because we may participate in advertising networks. Ad networks may allow JM-HM to target its messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information JM-HM’s ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection may take place both on the Site and on third-party websites and apps that participate in the ad networks. This process also helps JM-HM track the effectiveness of its marketing efforts.
The Site is not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/.
INFORMATION WE DISCLOSE TO OTHERS
JM-HM does not disclose Personal Data it obtains about you through the Site or other channels covered by this Online Privacy Notice, except as described in this Online Privacy Notice. As applicable, JM-HM may share your Personal Data with its affiliates and subsidiaries. Depending on the nature of JM-HM’s relationship with you, JM-HM also shares Personal Data with service providers who perform services on JM-HM’s behalf, JM-HM’s financial and transaction counterparties, JM-HM’s professional advisors, and your agents and representatives. JM-HM does not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.
JM-HM also may disclose information about you (i) if it is required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when JM-HM believes disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. JM-HM reserves the right to transfer Personal Data it has about you in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
In addition, JM-HM may share anonymous / aggregated information with third parties, such as service providers, in order to facilitate JM-HM’s business operations.
Information collected through third-party plug-ins and widgets on the Site (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and JM-HM is not responsible for those providers' information practices.
RETENTION AND DELETION OF YOUR INFORMATION
JM-HM intends to keep your Personal Data accurate and up-to-date. JM-HM will delete the information that it holds about you when it no longer needs it. JM-HM retains your Personal Data for as long as it is required by JM-HM for its legitimate purposes, to perform its contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to JM-HM.
JM-HM will retain your information for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that JM-HM may retain some limited information about you (even when JM-HM knows that you have left the organization that you represent) so that JM-HM can maintain a continuous relationship with you if and when JM-HM is in contact with you again.
YOUR RIGHTS AND CHOICES
JM-HM offers you certain choices in connection with the Personal Data it collects from you. To update your preferences or submit a request, please contact us as indicated in the "How to Contact JM-HM" section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to JM-HM’s processing of your information, you may request access to the Personal Data JM-HM maintains about you or request that JM-HM correct, amend, delete or block the information by contacting JM-HM as indicated below. Where provided by law, you may withdraw any consent you previously provided to JM-HM or object at any time on legitimate grounds to the processing of your Personal Data, and JM-HM will apply your preferences going forward. You can also lodge a complaint about JM-HM’s processing of your Personal Data with the body regulating data protection in your country.
These rights may include:
Rights of access, correction and deletion. You may have a right of access to the Personal Data that JM-HM holds about you, and to some related information, including the purpose for processing the Personal Data, the recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source. You may also have the right to require any inaccurate Personal Data to be corrected or deleted.
Right to object, and portability. You can object to JM-HM’s use of your Personal Data for direct marketing purposes at any time and you may have the right to object to JM-HM’s processing of some or all of your Personal Data (and require them to be deleted) in some other circumstances. In some circumstances, you may also have a "data portability" right to require JM-HM to transfer your personal data to you or a third party.
If you wish to exercise any of these rights, please contact us as set out below.
Complaints. You can also lodge a complaint about JM-HM’s processing of your Personal Data with the body regulating data protection in your country.
HOW JM-HM PROTECTS PERSONAL DATA
JM-HM maintains internal and third-party administrative, technical and physical safeguards designed to protect Personal Data JM-HM obtains through the Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
LINKS TO OTHER WEBSITES
The Site may provide links to other websites for your convenience and information. These websites may operate independently from JM-HM. Linked websites may have their own privacy notices or policies, which JM-HM strongly suggests you review. To the extent any linked websites are not owned or controlled by JM-HM, JM-HM is not responsible for their content, any use of the websites, or the privacy practices of the websites.
UPDATES TO JM-HM’S ONLINE PRIVACY NOTICE
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in JM-HM’s Personal Data practices. JM-HM will post the updated version on the Site and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.
HOW TO CONTACT JM-HM
If you have any questions or comments about this Online Privacy Notice, or if you would like JM-HM to update information JM-HM has about you or your preferences, please email JM-HM at the following address: jmhiggins@justinmhiggins.com.