Last Updated: June 30, 2020
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we may collect and and/or may have collected over the past 12 months:
Category of Personal Data Collected
|Categories of Third Parties With Whom We Share this Personal Data for a Business Purpose:|
|Contact Data (e.g., name, username, email, phone number, address)||· Service providers|
|Account Data (e.g., topical or geographic interests, search parameters, your use of the Services)||· Service providers|
|Log Data (e.g., IP address, data and time of Services usage, device ID, domain server, device type, browser type, operating system statistics, search queries)||· Service providers|
|Web Analytics (e.g. referring source through which you access the Services; non-identifiable request IDs, statistics regarding interaction between device/browser and the Services, links to third party applications used through the Services, dashboard interactions, website clicks, new windows opened)||· Service providers|
|Geolocation Data (e.g., location data if opted in through your mobile device)||· Service providers|
|Publicly-Available Content Provided through the Services, Including Social Media Information (e.g. profile information such as usernames, followers, number following, URL, location, language, tags, profile image, verified status, hashtags; profile content such as description, occupation, preferred channels, likes; post content such as tweets, status updates, timestamp, hashtags, language, geolocation)
Please note we do not collect the foregoing publicly-available content as a result of your use of the website or Services
· Service providers
Categories of Sources of Personal Data
We may collect Personal Data about you from the following categories of sources:
How We Use Your Personal Data
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section.
We may share any Personal Data that we collect with relevant third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “How We Use Your Personal Data” section above.
All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should any of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
You can decide whether to accept Cookies through your Internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionality may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements on our behalf. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you or derived from usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for our advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. We store information in paper-based files or electronic records in secure databases in the EEA, the U.S., and Australia (including trusted third-party storage providers). Personal Data may be collected in paper-based documents and converted to an electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorized access, modification or disclosure. We maintain physical security over paper and electronic data storage, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems. The Services use industry standard Transport Layer Security (TLS) technology to allow for the encryption of Personal Data you provide to us.
You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at email@example.com.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of the exceptions under the CCPA, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
Under some state laws, including the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Except for these sales through third party Cookies, we don’t sell your Personal Data. You can opt out of these sales by following the instructions in this section.
We may sell your Personal Data to the following categories of Third Parties:
Over the past 12 months, we may have sold the following categories of your Personal Data to the above-referenced Third Parties:
You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Privacy Act Systems of Records
When Dataminr operates a system of records subject to the Privacy Act of 1974 or comparable U.S. government agency regulations, including any use of information contained in such a system of records, our use and disclosure of that information (“Privacy Act Information”) is subject to the applicable Systems of Records Notice and applicable agency regulations, which control to whatever extent they may conflict with this Policy. Dataminr employees who create, receive or otherwise handle Privacy Act Information are required to undergo initial and annual Privacy Act training as a condition of their access to the information. Dataminr prohibits any unauthorized use of a system of records or unauthorized disclosure, access, handling, or use of Privacy Act Information. Any person can report a suspected or confirmed breach of Privacy Act Information or the unauthorized disclosure, access, handling, or use of Privacy Act Information to Dataminr using the contact information below.
European Union Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation or equivalent applicable legislation in your jurisdiction (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Dataminr will be the controller of your Personal Data processed in connection with the Services.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above identifies the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “How We Use Your Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing primarily include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Examples of these legitimate interests include (as described in more detail above):
Sharing Personal Data
The “How We Share Your Personal Data” section above identifies how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at firstname.lastname@example.org.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if a request is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances we will still respond to notify you of such decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
International Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Dataminr and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside and may not provide equivalent levels of data protection as such jurisdiction. The recipients of such Personal Data may be located in the EEA, the U.S., Australia, and possibly other countries. We will comply with applicable laws when transferring your Personal Data overseas, including taking reasonable steps to ensure that your Personal Data receives an adequate level of protection in the jurisdictions in which we process it. Such protections may include: (i) implementing a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) implementing binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adhering to an industry- or technology-specific approved code of conduct approved by the European Commission.
Communications from Dataminr
If you do not want to receive marketing communications from us, please indicate your preference by emailing us at email@example.com or otherwise following the instructions included in the email or changing your email preferences in your account settings. Even if you opt out of receiving such communications, we may send you non-marketing communications (such as Services-related communications or notices required by law).
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are outside of the EEA you may wish to take your request or complaint up with the local data protection authority in your jurisdiction.