Last updated: Jan. 1, 2020

This privacy policy (“Privacy Policy” or “Policy”) governs the data collection practices by us, Pluralist Media, LLC (“Company”, “we” or “us”), while you (“you”, “yours” or “user”) access and use our website: http://pluralist.com/ (“Website”) and the content provided therein content (“Website Content”).

Our users’ privacy is important to us therefore we encourage you to read the Privacy Policy carefully prior to accessing or using our Website and use it to make informed decisions. This Privacy Policy provides important and transparent disclosures on how or why we collect, share and use our users’ data.

Subject to applicable law, our lawful basis for processing Personal Information is as follows:

1. We process certain Online Identifiers (as described below) during your use of our Website and for functionality and operational purposes, which we have a legitimate interest in processing;
2. We and our third party partners may use cookies for advertising purposes, which, subject to applicable law requirements, we will request your consent for us to do so; and
3. In the event you contact us, we will process your contact details and other information you choose to provide us in order to perform our contract with you.

This Privacy Policy constitutes an integral part of our Terms of Use. Definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms of Use.

If you have any questions about this Policy, please contact us at: care@pluralist.com (or as described below).

AMENDMENTS

We reserve the right to periodically amend or revise the Privacy Policy. The revised terms will be effective immediately upon the display of the revised Privacy Policy. The last revision date will be reflected in the “Last modified” heading. In the event of amendments that will substantially change our privacy practices, we will make a reasonable effort to provide an applicable notification of such amendment. We recommend you review this Privacy Policy periodically to ensure that you understand our privacy practices

INFORMATION COLLECTED

During your access or any interaction with our Website we may collect aggregated, non-personal non-identifiable information that may be made available or gathered via the users’ access to and use of the Website (“Non-Personal Information “). We are not aware of the identity of the user from which the Non-Personal Information is collected. We may disclose or share this information with third parties as specified below and solely if applicable. We may also collect from you during your access or interaction with the Website individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Information”). The types of information that we collect as well as the methods that we use to collect such information are specified in the table below.

Type of Information	Purpose of Processing
Technical Information:We may collect technical Non-Personal Information from you. This information includes the type of device, operating system and browsers you use, the time and date you accessed the Website, User’s actions (i.e., regarding your viewing and interaction with the Website and Website Content, including visited web pages and clickstream), your approximate geographical location and any redirecting URLs.	We collect this information solely to operate, provide, maintain, protect, manage, customize and improve our Website and the Website Content.
Contact Details:If you voluntarily contact us in any manner, or for any request or notification, whether by submitting an online form that we make available through the Website (i.e., “Contact Us” page) or by sending an email to an email address that we display, or in any other manner, you may be required to provide us with certain information such as your name and email address which we will then process.	We will use your contact details only in order to respond to you, provide you with support, assist you or provide you with any other service that you request.
Online Identifiers:We may collect certain online identifiers, such as your IP addresses, for advertising, optimization, performance and analytic purposes, all as detailed in this Privacy Policy.	We use Online Identifiers for:(i) our legitimate interests of operating, providing, maintaining, protecting, managing and improving our Website and the Website Content; (ii) enhancing your experience and optimizing the Website Content based on your preferences; (iii) performing research, as well as for analytical and statistical purposes; (iv) our legitimate interests of auditing and tracking usage statistics and traffic flow, auditing our affiliates, calculating payments, detecting fraud, security or technical issues in connection with the Website, and (v) advertising purposes. The Online Identifiers might be collected by us or by our third-party affiliates, analytic, optimization partners and advertisers, which their Cookies we use in our Website, as detailed in the “Cookies” section below.

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Website, we may collect the above detailed information from you, as follows:

• In the event you voluntarily choose to provide us with information, when you contact us.
• Automatically, including through the use of cookies (as detailed below), and other similar tracking technologies.

In the event required under applicable law and technically possible, we will ask for your consent to collect Personal Information, as well as offer you the choice to opt-out.

COOKIES

When you access or use the Website or the Website Content, we may use “Cookies” and similar tracking technologies. The use of Cookies is a standard practice. A “Cookie” is a small piece of information that a website assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. Cookies are also used to help customize your experience. You can find more information about cookies at www.allaboutcookies.org.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions of your device preferences (as detailed below). However, if you choose to disable cookies, some features of the Website may not operate properly and your online experience may be limited.

Types of cookies used on our website:

There are several types of cookies that we use on our Website as follows:

• Essential, Functionality, Operation and Security Cookies. These cookies are essential for enabling user movement around the Website, for the Website to function properly, and for security purposes (e.g., prevent fraudulent use). This category of cookies either cannot be disabled, or if disabled, certain features of the Website may not work.
• Analytic, Measurement and Performance Cookies. These cookies are used to collect information about how users use our Website, in order to improve our services and the way we offer them, as well assess performance of the Website Content and the way it is displayed on our Website.
• Targeting and Advertising Cookies. These cookies are set through our Website by our advertising partners. They may be used by these companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and device and allowing the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of utmost interest to you. This Privacy Policy does not cover the use of cookies by any third party advertisers nor such third party advertisers’ related privacy practices, which have not been reviewed or examined by us. We encourage you to carefully read the privacy policies of all third parties whose services we use on the Website. The third party cookies that we currently use, the reason why we use them and their privacy policies are located in the table below.

Third Party	Purpose	Privacy Policy
Google Analytics	Analytic, Measurement and Performance	https://policies.google.com/privacy https://tools.google.com/dlpage/gaoptout https://policies.google.com/technologies/managing?hl=en
Google AdSense	Targeting & Advertising
Google AdWords	Targeting & Advertising
Google Tag Manager	Essential, Functionality, Operation and Security
Alexa	Analytic, Measurement and Performance	https://www.alexa.com/help/privacy
Quantcast	Analytic, Measurement and Performance	https://www.quantcast.com/privacy/
ComScore	Analytic, Measurement and Performance	https://www.comscore.com/About/Privacy-Policy
GeoEdge	Essential, Functionality, Operation and Security	https://www.geoedge.com/privacy
Forensiq/Impact	Essential, Functionality, Operation and Security	https://impact.com/privacy-policy/
ProtectedMedia	Essential, Functionality, Operation and Security	https://www.protected.media/privacy-policy/

For additional information with regards to our use of Google products, click here.

Opt Out:

You may easily opt out of the data collection, sharing process and targeted advertising services related to our Website, as follows:

• You may set your browser to block all cookies, including cookies associated with our Website, or to indicate when a cookie is being set by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. The following are some links which you may find useful:
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
• Safari: https://support.apple.com/kb/PH21411;
• Edge: https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies, and
• Opera: https://help.opera.com/en/latest/security-and-privacy/;

• You may opt-out of each cookie category listed above (except strictly necessary cookies) by using the cookie management tool provided on the Website to change your settings preferences.
• You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
• As detailed above, we use third-party advertising companies to serve ads when you visit our Website. These companies may collect certain information about you in order to provide advertisements about goods and services of interest to you. These third party advertisers may provide ways for you to opt out from or limit their collection of information from and about you. Please refer to these third party’s privacy policies to learn more. Please see: http://www.networkadvertising.org/managing/opt_out.asp for more information.

Note that once you opt out, part of the services provided by us might no longer be available and some features may not work if you revoke the data transfer. In addition, note that even if you opt-out, you may still receive content and advertising, however it will not be targeted

SHARING DATA WITH THIRD PARTIES

We do not share any Personal Information collected from you with third parties or any of our partners except in the following events:

• Law Requirement: We will share your information solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with a court injunction, comply with tax authorities, etc.);
• Policy Enforcement: We will share your information solely to the extent needed to enforce our policies and agreements, investigations of potential violations thereof, including without limitations, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
• Company’s Rights: We will share your information solely to the extent needed to establish or exercise our rights to defend against legal claims and subject to applicable law;
• Third Party Rights: We will share your information solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party;
• Affiliated Companies and Corporate Transaction: We may share your information with our parent company, any subsidiaries, joint ventures, or other companies under common control (“Affiliated Companies “) solely if and when applicable or necessary for the purposes described in this Privacy Policy, as well as in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy; and
• Online Identifiers: We may share Online Identifiers in order to calculate our advertising partner’s payments and detect fraud.

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non Personal Information to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

USERS’ RIGHTS

Data protection and privacy laws provide you with the following rights regarding your Personal Information, which you may exercise:

• You may request us to confirm whether we process certain of your Personal Information, provide you with a copy of such Personal Information, and provide you with more information with respect to why and how we process such Personal Information;
• You may request the rectification of your Personal Information that we hold that is not accurate and to oblige us to inform third parties that we transferred such Personal Information to that such Personal Information is inaccurate;
• You may request the erasure of your Personal Information that we hold (known as the “right to be forgotten”) provided that certain conditions have been met. These conditions are: We are required to comply with a request to exercise the right to be forgotten and delete the requested personal data if: (i) the applicable Personal Information is no longer needed for the original purpose for which it was collected and in addition, there is no new lawful basis for continued processing; (ii) the lawful basis for processing is consent and you requested to withdraw the consent provided by you; (iii) you have exercised your right to object to the processing of your Personal Information by us, and we have no overriding grounds for the processing of such Personal Information; (iv) the Personal Information is processed by us unlawfully, or otherwise, the erasure of your Personal Information is necessary to comply with applicable laws. In addition, in the event we have transferred your Personal Information to a third party, you have the right to request of us to ask those third parties to erase such information. Please note that, this right to erasure is not absolute. Even if you fall under the aforesaid conditions, we are entitled to reject your request to erase the information in the event that we find it (subject to applicable laws): (i) necessary to comply with legal obligations; (ii) necessary to establish, exercise or defend legal claims; or (iii) necessary for scientific purposes, etc.;
• You may request to restrict processing of your Personal Information in the event that: (i) the accuracy of the Personal Information is contested; (ii) restriction is requested instead of erasure where the processing is considered to be unlawful; (iii) we no longer need the Personal Information for its original purpose, but the data is still required to establish, exercise or defend legal rights, or (iv) consideration of overriding grounds in the context of an erasure request;
• You may object to the processing of your Personal Information by us with respect to Personal Information that is being processed by us under the lawful basis of our legitimate interests. However, even if we receive your objection, we will be permitted to continue processing the Personal Information in the event that (subject to applicable laws and regulations): (i) our legitimate interests for processing override your rights, interests and freedoms, or (ii) the processing of such personal data is necessary to establish, exercise or defend a legal claim or right, etc.;
• You may request to exercise your right for us to send or “port” your Personal Information to a third party. Such request can only be made if: (i) you have provided us with the Personal Information; (ii) it is processed automatically; (iii) it is processed on the legal bases of either consent or fulfilment of a contract;
• You may exercise your right to file a complaint to a supervisory authority in your jurisdiction, and
• You have the right to withdraw consent.

In the event that you contact us and request to exercise any of your rights detailed above, we may require certain information from you in order to verify your identity and locate your data. Such process may take up to one (1) month, subject to applicable privacy law.

Please note that, you may have different rights than those that we listed above depending on and according to privacy protections laws in your jurisdiction.

If you wish to be provided with more information, you would like to exercise your rights, or in the event that you have any additional complaints about your privacy rights, please initially contact us at: care@pluralist.com.

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here and send it to our Data Protection Officer at: care@pluralist.com.

DELETING DATA

Unless you instruct us otherwise, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable, in accordance and compliance with applicable laws. However we will not retain information for longer than twenty four months in an identifiable form or as required by law.

In the event that you do not agree to the aforesaid collection, use and sharing of data, please cease your use or accessing of the Website. If you have provided us with Personal Information by contacting us, such as your name and email address, and you wish to remove such information please contact us.

SECURITY

We use physical, technical and administrative security measures for the services that we believe are in compliance with applicable laws and industry standards.

Please contact us at: care@pluralist.com if you feel that your privacy was not dealt with properly in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Information. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

CHILDREN

Our Website is not directed nor is it intended for use by children (under the age defined by applicable law and specifically under the age of 16 within the EEA, and under the age of 13 within the U.S.) and we do not knowingly process children’s information. In the event that we become aware that a user who is considered a “child” under applicable law has shared any information with us, we will discard such information. If you have any reason to believe that a child has shared any information with us, please contact us at: care@pluralist.com.

DATA TRANSFER

We may store or process your Personal Information in the United States or in other countries. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Information requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

DO NOT TRACK DISCLOSURE

The Website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

CONTACT US

If you have any questions about this Privacy Policy, you may contact us in one of the following ways:

• Through our online form available in the Website, or
• By sending an email to: care@pluralist.com.

DATA PROTECTION OFFICER

In addition to the above, if you wish to exercise your rights related to your Personal Information, or you have any requests regarding the collection of your information by us, you may contact our Data Protection Officer at: care@pluralist.com

Please be sure to include your name, address and email address in any correspondence so that we can respond to your inquiry or request.