Consumer Data Privacy

Background:

Viamedia, Inc. (“Viamedia”) is committed to protecting the privacy and the security of independent consumers (“Consumer(s)”), its business partners (“Partner(s)”), and all of its collected data, including data provided to Viamedia by those Consumers and Partners (“Consumer Data”).

 

Viamedia maintains security policies and procedures designed to ensure no unauthorized person or business has access to Consumer Data. These policies cover each of its products and services (the “Service(s)”), whether the Services are provided through the Viamedia website or any other direct access portals available to Consumers, or through websites and direct access portals operated by its Partners. Such policies set forth how Viamedia uses and stores the Consumer Data it collects and receives (the “Consumer Privacy Policy”).

 

Viamedia uses a variety of multi-level security procedures to limit the information it onboards and to protect the privacy and security of all Consumer Data, including administrative, technical, and physical safeguards designed to protect personally identifiable information against unauthorized access, use, or disclosure of any information that can be used to individually identify a person, and may include, but is not limited to, name, phone number, email address, IP address, postal or other physical address (“PII”).

 

California Notice of Collection

If you are a resident of California, please see the California Addendum: URL FOR CALIFORNIA ADDENDUM. This Addendum includes additional information provided pursuant to the California Consumer Privacy Act of 2018 as amended from time to time (“CCPA”). This Addendum includes information regarding categories of information to be collected, the purposes for which the categories of information are collected or used, whether the information is sold or shared, how to opt out, and how long information is retained.

 

What Data do we Collect?

Viamedia may collect personal information such as:

Your name

Email address

IP address

Geolocation data, derived from your IP address

Internet activity

And other inferences that may be derived from third parties’ information collected about you.

 

Collection and Processing of PII:

Viamedia onboards, processes, and uses Consumer Data solely in accordance with the purposes stated within this Consumer Privacy Policy. Consumer Data is stored on servers operated by Viamedia’s Partner, Launch Labs, in accordance with its privacy policy, which is available at: https://www.launchlabs.ai/privacy-policy/ (the “Secure Servers”). The Launch Labs policy may be modified independently of this Consumer Privacy Policy; however, such modifications will never result in a material reduction to the level of data protection provided. The Secure Servers are located in the United States of America and are used to provide the Services in conjunction with and according to the instructions of Viamedia’s Partners. All Consumer Data is collected for the purposes of targeted advertising and event promotion.

 

How we Collect Consumer Data

Certain Consumer Data may be automatically collected from Consumers and attributed to a unique anonymous ID, via web beacons, Google Analytics, or other analytic and tracking technologies through a script or tag Viamedia places on a Partner website, or upon interaction by a Consumer with the Services or visitation to a Viamedia or Partner website employing the Services. The exact data collected is dependent on the device settings employed by that Consumer, and may include, but is not limited to, IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, or information about how and when Consumers use Viamedia’s Services. This automatically collected Consumer Data is primarily used for internal analytics and reporting purposes.

 

Voluntary Consumer Data will be collected as provided by Consumers. This voluntarily provided Consumer Data is collected when that Consumer registers on the Services, expresses an interest in obtaining information through the Services, participates in activities on the Services, or otherwise contacts Viamedia or a Partner. This information may include, but is not limited to, PII such as name, phone number, email address, or postal or other physical address.

 

Additional Consumer Data may be collected from third party sources, including Partner and affiliate programs, data providers, and public databases. This information may include, but is not limited to, postal or other physical address, job titles, email address, phone number, Consumer behavior data, IP address, social media profiles, or social media URLs. This Consumer Data may be used to facilitate cross-context behavioral advertising, allowing for finely focused advertising based on Consumer behavioral data across a variety of websites and services.

 

Viamedia operates advertising campaigns on behalf of advertisers and may leverage ID-based audience segments provided by reputable third-party partners. These audience segments allow Viamedia to deliver more relevant advertisements to Consumers based on their interests and demographics.

 

Consumer Data we do not Collect

Viamedia does not knowingly solicit data from or market to children under 18 years of age, nor does it solicit sensitive information of any kind, including but not limited to, social security number, driver’s license number, credit/debit card, financial account number, or personally identifiable payroll information. By using the Services, Consumers represent that they are at least 18 years of age and are not providing unsolicited sensitive information.

If Viamedia becomes aware that personal information from Consumers less than 18 years of age or sensitive information has been provided by a Consumer, it will discontinue the Services being provided to that Consumer and take reasonable measures to promptly delete such data from its records. If a Partner becomes aware that any prohibited Consumer Data has been collected, it should contact Viamedia as set forth below to ensure prompt deletion.

 

Storage, Access, and Deletion of Consumer Data:

Viamedia does not rent, sell, or share Consumer Data with other individuals or companies other than the Partner who operates the website through which the Consumer engaged the Services, and with Launch Labs as necessary to facilitate storage on the Secure Servers; however, certain Consumer Data may be shared in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Viamedia’s business to another company. Consumer Data may also be shared with certain Google Maps Platform APIS to retrieve certain information when location-specific requests are made by Consumers, including but not limited to, name, address, location, dwelling type, email, or phone number.

 

Additionally, Consumer Data may be shared in response to subpoenas, court orders, or legal process, or to establish or exercise Viamedia’s legal rights or defend against legal claims, or as needed in order to investigate, prevent, or take action concerning illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violation of Viamedia’s terms of service, or as otherwise required by law.

 

Viamedia may engage third party service providers, as well as its affiliates and subsidiaries, to provide a subset of Services. Only Consumer Data that is specifically needed to execute such Services is shared and transferred to such third party service providers pursuant to an agreement with that third party service provider and through secure transmission methods and protocols.

 

How we store Consumer Data

Consumer Data is stored on the Secure Servers in an encrypted format, or is otherwise password protected, and is maintained in a secure environment that limits access only to those Viamedia or Launch Lab employees who have a need to access the Consumer Data in this same secure manner. All Consumer Data remains the exclusive property of Viamedia, with Launch Lab employees having access only as necessary to identify or resolve technical problems, or as required by law. Viamedia’s Partners and third-party service providers are required to maintain data security and privacy protections at least as stringent as those maintained by Viamedia. For Services that include data match by Viamedia’s third party service providers, data is matched in a privacy-compliant manner that creates an anonymous targeting pool. Viamedia’s third party service providers are required to securely delete Consumer Data upon completion of these Services.

 

While Viamedia does not directly store Consumer Data, in some cases Consumer Data may temporarily reside on a Viamedia system.  Viamedia takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of all data, including Consumer Data. These measures include internal review of its data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where the data is stored. All Viamedia systems have antivirus protection and are protected by a hardware firewall, which provides ongoing screening, and automatic prevention, of potential security threats. Alert logs from the firewalls are reviewed daily, and periodic vulnerability scans and penetration tests of the network are run to ensure ongoing system security. Viamedia maintains strict physical security for its facilities and limits access to its facilities to authorized Viamedia employees and invitees. Viamedia will securely delete any Consumer Data that is temporarily stored on its systems as soon as it is no longer necessary for the provision of the Services.

 

Despite these safeguards, no electronic transmission over the internet or information stored technology can be guaranteed to be completely secure. Viamedia cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat this security, or the security in place on the Secure Servers, and improperly collect, access, steal, or modify Consumer Data. Transmission of PII to and from the Services is at the risk of the Consumer.

 

Once Consumer Data is no longer needed to provided Services, it is securely deleted using industry standard data overwrite protocols.

 

Right to Delete, Access, and Correct

Consumers and Partners may request access to the Consumer Data collected by Viamedia. Consumers and Partners may also ask for the deletion or correction of their PII. If a Consumer asks for their individual PII, Viamedia will respect that request and delete or correct their PII, subject to certain exceptions provided by law, including, but not limited to, the exercise by another Consumer’s right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

 

To request access to, deletion or correction of your PII or Consumer Data, please refer to the “Updates and Contact” section of this Consumer Data Privacy Policy.

 

Consumer Rights:

Consumers located in the EEA or UK who believe Viamedia is unlawfully processing their PII have the right to complain to their local data protection supervisory authority.

Viamedia is relying on Consumer consent, which may be express and/or implied depending on the applicable law and the pertinent PII. Consumers have the right to withdraw their consent or request to access, change, or delete their PII at any time by contacting the applicable Partner employing the Services, who must then pass such request onto Viamedia. Please note withdrawal of consent will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Consumers may withdraw consent and/or opt-out of further communications or Services, or change or request deletion of any collected data by contacting the Partner or by contacting Viamedia as set forth below.

 

If Viamedia denies a Consumer’s request to exercise any of the above rights, Consumers may appeal that decision by contacting Viamedia at the address provided in the “Updates and Contact” section below. In the appeal request, Consumers should describe the basis for the appeal and provide any additional information that may support their request. Viamedia will respond to appeals within sixty (60) days of receipt.

 

State-Specific Privacy Rights:

Residents of certain states may have additional privacy rights under applicable state law. If you are a resident of California, please see our California Addendum for information about your rights under the California Consumer Privacy Act.

 

In addition to the rights described above, residents of certain states have the following rights under their state’s consumer privacy law. This list will be updated as additional state privacy laws take effect:

Right to Opt Out of Targeted Advertising. Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Utah, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Maryland, Minnesota, and Tennessee may opt out of the processing of their personal data for purposes of targeted advertising. Targeted advertising means displaying advertisements to you based on personal data obtained or inferred from your activities over time and across nonaffiliated websites or online applications.

Right to Opt Out of Profiling. Residents of Virginia, Colorado, Connecticut, Texas, and Oregon may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning them. Profiling means any form of automated processing of personal data to evaluate, analyze, or predict personal aspects concerning an identified or identifiable individual.

Right to Obtain List of Specific Third Parties. Residents of Oregon may request a list of the specific third parties to whom Viamedia has disclosed their personal data, rather than merely categories of third parties.

Global Privacy Control. Residents of California, Colorado, Connecticut, Texas, and Montana may use Global Privacy Control (“GPC”) or similar universal opt-out mechanisms to communicate their privacy preferences. GPC is a browser-based signal that allows Consumers to opt out of the sale or sharing of personal data and targeted advertising. For residents of these states, Viamedia will process a GPC signal from your browser as a valid opt-out request, as applicable under your state’s law. For more information about GPC, please visit https://globalprivacycontrol.org/.

 

To exercise these rights, please contact Viamedia as set forth in the “Updates and Contact” section below.

 

Additional Opt-Out Resources:

In addition to the opt-out methods described above, Consumers may visit the following industry resources to learn more about interest-based advertising and exercise additional opt-out options offered by participating industry members: the Digital Advertising Alliance at https://youradchoices.com/ and the Network Advertising Initiative at https://optout.networkadvertising.org/. Please note that these industry programs are supplemental resources and do not replace Viamedia’s own opt-out mechanisms. To opt out of Viamedia’s processing of your personal data, please contact Viamedia directly as set forth in the “Updates and Contact” section below.

 

Updates and Contact:

This Consumer Privacy Policy will be updated as necessary to remain compliant with relevant laws. The updated version will be indicated by an updated “Revised” date, with the updated version effective as soon as it is publicly accessible. If material changes are made, Consumers and Partners may be notified either by prominent posting of the changes or through direct notification. Launch Labs, in maintaining its privacy policy, may update such policy independently of this Consumer Privacy Policy. That privacy policy, and records as to its modifications, can be accessed at: https://www.launchlabs.ai/privacy-policy/.

 

Partners and Consumers with specific concerns, questions or comments related to this Consumer Privacy Policy or Viamedia’s procedures and protocols regarding Consumer Data, or who wish to correct inaccuracies in Consumer Data, or to request that Viamedia delete Consumer Data, may contact Viamedia at info@viamediatv.com, or Customer Service, Viamedia, Inc., 220 Lexington Green Circle, Suite 300, Lexington, Kentucky 40503.