Last updated: May 16, 2016
CG Media, LLC d/b/a CitrinGroup Media (“CitrinGroup Media”) is an independent publishing and public relations firm that strives to promote the core philosophy of Jonathan Citrin, a financial advisor, media commentator, international speaker and author.
What Information Do We Gather?
What Do We Do With the Information We Collect?
Who Can Use the Information We Collect and How?
How Do We Protect the Personal Information We Collect?
How Do You Opt-out of Personal Information Sharing with Our Business Partners?
What Happens When You Link to a Third-Party Web Site?
What Happens If We Sell Our Business?
Your California Privacy Rights
Your International Privacy Rights
What If You Have Questions?
1. What Information Do We Gather?
CitrinGroup Media may need to collect certain information about you, whenever you interact with our sites and/or use our services. This information includes your personal information. “Personal information’’ refers to information about you that alone or in combination with other information may be used to readily identify, locate, or contact a specific person and includes: full name, address, phone numbers, email address, financial and/or payment information (if applicable). The information we gather from our customers allows us to personalize and improve our services. The information we gather may include, but is not limited to:
- Contact information including email address and cell phone number
- Demographic information including messageal code, product preferences and interests
- Internet Protocol (“IP”) Address and other persistent identifiers
- Other information relevant to customer surveys and offers
Some of this information, including name and contact information, will only be collected if you voluntarily provide it during the user registration process and as you enter information on our site. From time to time, we may use or augment your personal information with information obtained from third parties. For example, we may use the third party information to confirm contact or financial information, verify eligibility or to better understand your interests based on demographic information. If you choose to link your CitrinGroup Media account to other devices or services, such as calendars, smart devices, or wearables, we may collect information to your use of such services or devices. If these services or devices are administered by a third party, the applicable information practices are the responsibility of that third party.
We may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages. We collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our Site was found. We may collect IP addresses and website usage information from you when you visit our Site via the use of “cookies.” An IP address is a number that is assigned to your computer when you are using your browser on the Internet.
2. What Do We Do With the Personal Information We Collect?
You will be asked to provide personal information in certain fields on this Site that allow you to be able to use our Services. The personal information we collect is used only for the purpose we state at the time of collection or for purposes contained below. For example, our uses may include, but are not limited to, the following:
- We may use your email address to contact you about new features on the Site, or to provide you with other information that is relevant to your use of the Site.
- We or our affiliates may periodically send you promotional emails about new products, special offers or other information which we believe may be of interest using the email address provided.
- We may also communicate with you through our CitrinGroup Media platform or other means enabled by CitrinGroup Media services, such as text messages, push-notifications, or in-app messaging.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
- We may use your information to customize the website according to your interests.
- We may aggregate or de-identify data collected through CitrinGroup Media services and use it for any purpose
- We may disclose your information to respond to subpoenas, judicial processes, or government requests or investigations.
- We may use your information to protect the security of our Services, servers, network systems and databases or to protect our users and affiliates against liability or harm.
To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” the data, i.e., remove information that would confirm your identity. We will not use your personally identifiable information, however, to send commercial or marketing messages to you unless we have your continued consent for which you will have the ability to opt out by sending an email to firstname.lastname@example.org.
If you choose to allow CitrinGroup Media to share information with others, we may also use your personal information to communicate with others at your request. You can adjust your communication preferences by unsubscribing to our marketing emails.
We may also use the information you share or we receive from others, to conduct research and organize/analyze your information to provide you with a customized and beneficial CitrinGroup Media experience.
This Site does not collect personally identifiable information when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that we will not know your name, your email address, or any other personally identifiable information just because you browse the Site unless you:
- access the Site from a link in an email that we have sent to you; or
- access the Site or provide information and data from a device you have approved to communicate with your account.
In these cases we will know who you are based on the information you previously supplied to us. When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our Site function correctly and provide you the functionality that you expect to see. We also use this information to personalize content presented to you, better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.
3. Who Can Use the Information We Collect and How?
We may provide your information to third parties, or third parties may collect information from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. Other than those who act on our behalf and except as explained in this Policy, information you provide at this Site will not be transferred to unrelated third parties, unless we have your permission to do so. However, please note that personal information provided to this Site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
We will not rent, sell, or share your personal information with other people or nonaffiliated companies for their direct marketing purposes, except to provide services, or when we otherwise have your permission. We may share aggregate or de-identified data with third parties for any purpose.
We may share information, including your personal information with your permission. We may also employ other companies and service providers to perform tasks on our behalf and need to provide any information to them. These companies are authorized to use your personal information only as necessary to provide the services to us. We may access, preserve and disclose your personal information and content if we deem it required or appropriate to comply with law enforcement requests and legal process or to protect the rights, property and safety of you, CitrinGroup Media, or others.
4. How Do We Protect the Personal Information We Collect?
Your privacy and the security of your personal information are important to us. We maintain and protect the security of our servers and your personal information. To secure the information we collect online, prevent unauthorized access, maintain data accuracy and ensure only appropriate use of information, we have established appropriate physical, electronic and management safeguards. Unless you authorize unencrypted transmission, we will use industry standard encryption methods to protect your data transmission.
How Do You Opt-out of Personal Information Sharing with Our Business Partners?
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.
You may opt-out of third party targeted advertising or analytics in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above) or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases or search history.
However, you cannot opt-out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features and activities are functioning and used. We will also share this information in an aggregated form (meaning that no one individual person can be identified) within our company.
You can also opt out of our marketing emails at any time by contacting us at email@example.com.
We understand the importance of protecting the privacy of all individuals, especially the very young. Our services are intended for United States audiences over the age of 18. We neither target nor sell our products to children under the age of 13, and we do not knowingly collect personal information from them. Subscribing to our online service is restricted to adults who are either 18 years of age or older or as otherwise legally defined.
6. What Happens When You Link to a Third-Party Web Site?
We may on occasion update our Policy. Your acceptance of any minor changes to this Policy is indicated by your continued use of our Services. If we make any material changes to our Policy, we will message a notice about the change at a prominent location on our Site. We encourage you to periodically review our Site and this Policy for any changes.
8. What Happens If We Sell Our Business?
While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another company or individual, or that it might buy certain assets of another company or individual. If all or part of the company is sold, merged or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction. However, we will take steps to ensure that your personal information is used in a manner consistent with the provisions of our Policy.
9. Your California Privacy Rights
If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or messageal mail). You may contact us in two ways. Send email firstname.lastname@example.org
For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
If you are a California resident under the age of 18, and a registered user of any site where this policy is messaged, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly messaged. To make such a request, please send an email with a detailed description of the specific content or information email@example.com Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have messaged and that there may be circumstances in which the law does not require or allow removal even if requested.
10. Your International Privacy Rights
11. What If You Have Questions?
If you have questions or concerns regarding this statement, you should first contact us via email at firstname.lastname@example.org.