Effective: June 2020
1. INFORMATION WE COLLECT.
A. Information about You that You Provide. ERemedium, and/or its Service Providers (defined below), may collect information you provide directly to ERemedium and/or its Service Providers via the Service. For example, ERemedium collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.
B. Information Collected Automatically. ERemedium, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer, tablet or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of ERemedium with ERemedium-Collected PI, ERemedium does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or ERemedium-Collected PI.
The methods that may be used on the Service to collect Usage Information include:
Some information about your use of the Service and certain Third-Party Services may be collected using Tracking Technologies across time and services, and used by ERemedium and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain
ERemedium is giving you notice of the Tracking Technologies and your choices regarding them so that your consent to encountering them is meaningfully informed.
2. HOW WE USE THE INFORMATION WE OBTAIN.
3. INFORMATION WE SHARE WITH THIRD PARTIES.
ERemedium may share non-Personal Information, and Personal Information that is not deemed ERemedium-Collected PI hereunder (provided that ERemedium is aware of no restrictions on ERemedium’s use, if any), with our parent and its and our subsidiaries and affiliates (“Affiliates”), and unaffiliated third parties for any purpose permitted by applicable law. Without limiting the generality of the foregoing, we and third parties may convert your Personal Information, including ERemedium-Collected PI, to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third party activities are subject to their privacy policies and practices. ERemedium’s sharing of ERemedium-Collected PI is, however, subject to the following:
In addition, ERemedium may share your ERemedium-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of ERemedium assets, or transfer of all or a portion of ERemedium’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, ERemedium relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by ERemedium for any other marketing purpose unless ERemedium obtains consent from that person. Your contact information and message may be included in the communication.
6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”), including the 1st Party Publishers that participate in our Mobile Ad Service. These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts, images and photos between the Service and a Third-Party Service; “liking” or “sharing” ERemedium’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with ERemedium in a tweet or status update), your post may be used on or in connection with the Service or otherwise by ERemedium. Also, both ERemedium and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
ERemedium may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. This includes both in the operation of our Online Service and our Mobile Ad Service. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (collectively, “Interest-based Advertising”), which may include sending you an ad on a third party service after you have left the Service (i.e., “retargeting”). We also treat location-aware ads that are sent in part due to your device location as Interest-based Advertising, and our Mobile Ad Service employs such geo targeting.
7. DATA SECURITY AND MONITORING
ERemedium takes reasonable measures to protect ERemedium-Collected PI (excluding public USER CONTENT) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and ERemedium does not guarantee the security of your information collected through the Service.
8. INTERNATIONAL TRANSFER.
9. CHILDREN’S PRIVACY.
The Service is intended for a general audience and not directed to children less than 13 years of age. ERemedium will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that ERemedium does not control.
10. ACCESSING AND CHANGING INFORMATION.
ERemedium may provide web pages or other mechanisms allowing you to delete, correct, or update some of the ERemedium-Collected PI, and potentially certain other information about you (e.g., profile and account information); or contact us via email, call as mentioned on the website. ERemedium will make good faith efforts to make requested changes in ERemedium’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from ERemedium’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, ERemedium currently does not alter ERemedium’s practices when ERemedium receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but ERemedium is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. ERemedium is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. ERemedium supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expects that ad networks ERemedium directly engages to serve you Interest-based Advertising, and the 1st party Publishers that participate in our Mobile Ad Service, will do so as well, though ERemedium cannot guarantee their compliance. ERemedium is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our databases and the data bases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
13. CONTACT EREMEDIUM.
© ERemedium Private Limited 2020. All Rights Reserved.