Last Updated: September 1, 2021
Roundtable Media, LLC, together with its subsidiaries and its affiliated businesses (collectively, "Roundtable," "We," or "Us"), offers a digital media platform that allows content creators to monetize content by allowing Roundtable and these content creators to show advertisements on such content. We refer to the content creators as "Partners" and to the websites and apps that participate in our coalition as "Partner Content.
COLLECTION OF INFORMATION
Information You Provide to Us
• Account Information: If you wish to use the Services, such as to create or post content, comment on other person's content or to post your own content to Partners' content, or if you wish to receive updates or newsletters from Us or from our Partners, you will be required to create a Roundtable account. When you create an account or use our Services, We ask you to provide certain personally identifiable information such as your first and last name, email address, telephone number, address, and payment card information (collectively, "Personally Identifiable Information"). We may also ask for information such as a profile picture or your social profile information. If your content is supported by advertising or paid subscriptions, We also collect your payment information to allow Us to pay you in accordance with your agreement with us.
• Other Information: We also collect any other information you provide directly to us. For example, We collect information when you participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, apply for a job, communicate with Us via third party social media sites, request customer support, or otherwise communicate with us.
Information About Your Use of the Services
• Information You Post: We collect information about the content you post, including any articles, comments, or interaction with other users' content. We also collect information about how you use the Services, including the Partner Content you view and follow and how you interact with Partner Content.
• Automatically Collected Data: When you access or use our Services, We automatically collect certain technical information, including:
o Log and Usage Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your I.P. address, and the page you visited before navigating to our Services.
o Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
o Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers and Partners) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help Us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below.
Information We Collect from Other Sources:
• We may also obtain information about you from other sources. For example, We may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, and publicly available sources. Additionally, if you create or log into your account through a social media site or third-party service (like Facebook or Google), We will have access to certain information from that service, such as your name, email address, and profile picture, in accordance with the authorization procedures determined by such social media site or third-party service.
USE OF INFORMATION
We use the information we collect to provide our Services and to customize your experience with the Services, including to show content and advertising that We think is likely to be of interest to you. We also use the information We collect to:
• Communicate with you about products, services, and events offered by Roundtable and others, and provide news and information We think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Roundtable and others;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
• Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
To allow Partners to earn advertising from their content, We share identifiers that do not identify you personally but may identify your browser or device with Partners and advertising partners as described in the "Advertising and Analytics Services Provided by Others" section below. Our Partners may also collect their own identifiers for these purposes.
We may also share the information We collect as follows:
• With vendors, service providers, and consultants that perform services for us, including email providers, I.T. service providers, and web hosting providers;
• In response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If We believe your actions are inconsistent with our user agreements or policies, if We believe you have violated the law, or to protect the rights, property, and safety of Roundtable, Partners, or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership, including but not limited to Say Media; and
• With your consent or at your direction.
• We may also share aggregated information that cannot reasonably be used to identify you.
THIRD-PARTY LINKS AND SERVICES
ADVERTISING, ANALYTICS, AND IDENTITY SERVICES PROVIDED BY OTHERS
When you use our Services, We may share information that We collect from you, such as your email (in hashed form), I.P. address, or information about your browser or operating system, with our identity service providers, including LiveRamp Inc. LiveRamp returns an online identification code that We may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt-out of this use, please visit optout.liveramp.com/opt_out.
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
Roundtable is based in the United States, and We process and store information in the United States and other countries. Therefore, our service providers and we may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By using the Services or providing personal information to us, you consent to the transfer of your personal information to the United States and other countries that may not provide equivalent levels of data protection as your home jurisdiction.
• Account Information: You may update certain account information you provide to Us at any time by logging into your account. If you wish to delete or deactivate your account, please email Us at [email protected], but note that We may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
• Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
• Promotional Communications: You may opt-out of receiving promotional emails from Us by following the instructions in those emails. If you opt-out, We may still send you non-promotional emails, such as those about your account or our ongoing business relations.
If you wish to opt out of receiving promotional communications from a Partner, you may do so by following the instructions provided by the Partner.
We do not knowingly collect personal information from children under 13 and do not allow Partners to host content with Us that is intended for children under 13 to participate in our platform. If you are the parent or legal guardian of a child under 13 who provided personal information to us, please contact Us at [email protected]
INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA OR SWITZERLAND
If you are in the European Economic Area ("EEA") or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data. Note that Roundtable is the controller of your personal data when collected in the E.U., but that Partners also act as data controllers for the personal data that We share with them and any personal data that Partners may collect independent of our relationship with them. If you have any questions about processing your personal data by a Partner, you should contact the Partner directly.
Legal Basis for Processing
If you are in the EEA or Switzerland when We process your personal data, We will only do so in the following situations:
• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
• We have a legitimate interest in processing your personal data. For example, We may process your personal data to provide, secure, and improve our products and Services and to communicate with you about our Services.
• Such processing is necessary to comply with our legal obligations.
• We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
Data Subject Requests
You have the right to access personal data that We hold about you and ask that your personal data be corrected, erased, or transferred. You may also have the right to object, or request that We restrict, certain processing. If you would like to exercise any of these rights, you may contact Us as indicated below in the Contact Us section.
We store the information We collect on you for as long as is necessary for the purpose(s) for which We originally collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Questions or Complaints
If you have a concern about our processing of personal data that We are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Privacy Notice for California Residents
Last Updated: September 1, 2021
Information We Collect
We collect information that identifies, relates to, describes, references is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
In particular, We have collected the following categories of personal information from consumers within the last twelve (12) months:
Category / Example / Collected (YES/NO)
Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Example: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Example: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Example: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Example: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Example: Physical location or movements.
H. Sensory data.
Example: Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Example: Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Example: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from the following categories of sources:
• Indirectly from you. For example, from observing your actions on our Website. This may be done by Us or by third parties with whom We have agreements to operate within or in conjunction with our Platform or Services.
Use of Personal Information
We may use, share/sell, or disclose the personal information We collect for one or more of the following purposes:
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, We will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email, phone, or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about our consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose or share/sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When We disclose personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share your personal information with the following categories of third parties:
• Service providers.
• Partners. "Partners" are third-party content creators and publishers
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, We have disclosed the following categories of personal information for a business purpose:
• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
• Service providers.
Sales of Personal Information
In the preceding twelve (12) months, We have shared/sold the following categories of personal information:
• California Customer Records personal information categories.
• Protected classification characteristics under California or federal law.
• Commercial information.
• Internet or other similar network activity.
• Geolocation data.
• Sensory data.
• Professional or employment-related information.
• Inferences drawn from other personal information.
We sell your personal information to the following categories of third parties:
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that We disclose certain information to you about our collection and use of your personal information over the past 12 months. Once We receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), We will disclose to you:
• The categories of personal information We collected about you.
• The categories of sources for the personal information We collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom We share that personal information.
• The specific pieces of personal information We collected about you (also called a data portability request).
• If We sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that We delete any of your personal information that We collected from you and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), We will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for Us or our service provider(s) to:
• Complete the transaction for which We collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by:
Emailing Us at "[email protected]"
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows Us to reasonably verify you are the person about whom We collected personal information or an authorized representative, which may include: First name, last name, email address, postal address, phone number.
• Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if We cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, We do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We aim to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to 90 days), We will inform you of the reason and extension period in writing.
If you have an account with us, We will deliver our written response to the email address on file for that account. If you do not have an account with us, We will deliver our written response electronically to the email that you provided to Us as part of your request.
Any disclosures We provide may only cover the 12-month period preceding the verifiable consumer request's receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell you why We made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct Us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
You do not need to create an account with Us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request or for questions regarding our Notice for California Residents, please send an email to [email protected]
PRIVACY NOTICE FOR NEVADA RESIDENTS
Although We do not "sell" "covered information" of Nevada "consumers" as those terms are defined under Chapter 603A of the Nevada Revised Statutes, you may contact Us by sending an email to [email protected] and registering your email address so that We can provide you notice in the event We should do so in the future. At that future point, you will then have an opportunity to exercise your opt-out rights under that law subject to our verification. You can contact Us via [email protected] if you need to subsequently update your contact email for such notices. If you change your email address elsewhere in our Services, that change will not update your Nevada notice contact information. It is your responsibility to keep your Nevada notice contact information current.