Privacy

Madison Logic – Privacy Policy 

 Updated April 2018

Overview

Madison Logic, Inc., its subsidiaries and affiliates (collectively, “Madison Logic”, or “we”, “us”, “our”) respect the privacy and security of your personal data.

This Privacy Policy details the information that we may collect through registration forms, resource libraries, advertising units, widgets, websites and web pages, whether accessed via computer, mobile, tablet device or other technology (collectively, the “Platform”) as well as the collection and licensing of data through our third-party partners. It also sets out how such information may be used and/or shared with others, how such information is stored and safeguarded by us, and your rights in relation to its use in connection with our marketing activities. For the purpose of this Privacy Policy, personal data refers to information or pieces of information that could identify you, such as your name, job description, date of birth, e-mail address or mailing address (“Personal Data”).

By interacting with us, whether on the phone or online through this website, you agree to the collection, use and processing of your personal data in the manner and for the purposes described in this Privacy Policy.

Data Collection

Our purpose in collecting information is to help us provide you with better service, for example through notifications about special offers and promotions or other relevant content delivered through targeted advertising.

You may choose to use our services or to receive additional information from us, for example by submitting a registration form containing certain information in order to access free content. When you request our services or register to receive information, we collect the following Personal Data: your name, address, email address, and telephone number. We may also receive this information through one of our business partners. To help us to promote content that is relevant to you, we may add to this data any business profile information that we receive about you from other sources, such as your industry, company size and job title.

Data usage

Madison Logic may use the information we obtain, license and collect about and from you for a number of business purposes, including, for example, to: better tailor our website and promotional content to visitor interests; verify your profile information; deliver targeted advertising; inform our partners and Clients of your business-related interests; improve the Platform for internal business purposes; help our advertising partners and Clients better understand the audience they are reaching; and for any purposes we disclose at the time you provide your Personal Data or your consent to our use of the same.

We will only ask for Personal Data that is adequate, relevant and not excessive for these purposes.

Legal basis and purposes of data processing

 Whenever we process your Personal Data, we do so for a specific purpose on the basis of a legal justification. Processing of your Personal Data may be justified on one or several of the following bases:

1) Performance of a contract with you

In order to perform the services you request from us, as set out in the section “Madison Logic Services”, we use in particular the following data:

  • Contact details: your name, telephone number and e-mail address.
  • Account data: your Platform account data and other electronic identification data such as IP address and the data you add to your account such as your password, date of birth, gender and other information you share with us.
  • Communication data: your requests, any complaints you might have as well as any data you share with us if we communicate with you via e-mail, telephone or social media.

2) Legitimate interest of us or a third party:

Beyond the processing of your Personal Data for the performance of a contract with you, we process your Personal Data to safeguard our or third parties’ legitimate interests provided such interests are not overridden by your fundamental rights or freedoms. Therefore, we process your Personal Data in particular for the following purposes:

  • advertising and market- and opinion research purposes, provided you did not object against such use of your data (see section “Updating Personal Data and your Data Subject Rights” below);
  • improvement of our products and services including our website;
  • prevention and investigation of criminal offences (in particular fraud); and
  • defence or enforcement of legal claims.

3) Your consent

As far as you provide us with your explicit, informed consent (e.g. when you have consented to receive marketing e-mails from us and/or third parties we work with for certain products and services) for the processing of Personal Data, such consent presents the legal basis for the processing. You may withdraw your consent at any time by following the steps outlined below in the section “Updating Personal Data and your Data Subject Rights”. Please note that the withdrawal of your consent only has effect for the future and does not affect the lawfulness of processing based on consent before your withdrawal.

4) Compliance with a legal obligation

Any information referred to above under the section “Data Collection” may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

Tracking Technologies and Usage Information

We, Madison Logic, and our publishing partners, Clients, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer websites, track users’ movements around websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.  As to information submitted to, through or on our website, we may likewise use service providers to host content, host or implement blogs and forums, or conduct data and marketing analytics with respect to information captured.

Madison Logic may use a variety of technologies, including “cookies” that automatically or passively collect information from your computer, mobile device or other technology, when you  visit Madison Logic, partner or Client websites. We may also collect information in this way on a third party’s behalf when we serve advertisements and store your Personal Data in log files. Information collected may include your IP address, browser type, operating system, your responses to advertisements delivered by us, date and time, referring URLs and other information normally transmitted in HTTP requests (“Usage Information”).

Usage Information may also be associated with anonymous business profile information about you, such as your industry, company size, and job title. The purpose of this information is to keep the Platform updated and interesting to our users and to tailor content to each individual’s interests. Madison Logic does not use this information to discern your identity or to disclose your identity to any third party. Madison Logic stores Personal Data in a separate database from any Usage Information.

A cookie is a small file stored on a user’s device containing information about the user. We may use cookies to reduce or pre-populate registration fields so that you can receive free content more easily, deliver targeted advertising, or understand your interests and focus areas of research. We believe this enables us to provide users with a more meaningful online experience.

We use Local Storage Objects (“LSOs”) such as Flash to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity also use LSOs such as HTML5 and Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To learn how to manage privacy and storage settings for Flash cookies click here:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118

Advertising / Behavioral Targeting; How to Opt-Out

We may use third-party vendors to enhance the Platform (e.g. for purposes of retargeting). We do not share Personal Data with these third parties, but they may set and access their own cookies, pixel tags and similar technologies on your device and they may otherwise collect or have access to anonymous Usage Information.

When you use the opt-out mechanism, Madison Logic will no longer use or share any of your Personal Data or anonymous Usage Information, with the exception of Personal Data submitted within the last 30 days to access free content, which the Content Provider may access.

When you opt out of the Platform, we place a cookie on or otherwise identify your browser or device (and/or employ similar technology) to prevent future collection of Usage Information. Opting out of the Platform is not the same as blocking cookies. When you opt out of Madison Logic’s Platform, we will place a special Madison Logic cookie on (or otherwise identify) your device or browser in a way that informs our systems not to record information related to your business research activities. If you browse the web from multiple devices or browsers, you will need to opt out from each device or browser to ensure that we prevent personalization tracking on all of them. For the same reason, if you procure a new device, change browsers or delete the Madison Logic opt-out cookie (or clear all cookies), you will need to perform this opt-out task again.

Please note: This opt-out relies on a cookie and so if you wipe all of your cookies, we will no longer know that you have opted out.

Disabling Cookies

If you would prefer not to accept certain cookies, you may be able to do the following:

  • change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or
  • set your browser to automatically not accept any cookies.

However, not all browsers offer these features for all types of cookies and these techniques may not always work.

Please note:  As cookies are used for a variety of reasons, not all of which are marketing-related, disabling cookies may adversely impact your online experience.

Sharing of Personal Data

Except as set out in this Privacy Policy, we will not provide any of your Personal Data to any partners or other third parties without your consent.

We may share Personal Data and Usage Information with Clients.  We may also share with third parties: information other than Personal Data, such as aggregated demographics, user statistics, interest categories and Usage Information with third parties. We may combine your Usage Information with those of other users of the Platform in order to share trend information with third parties. Where we do so, this information will always be in aggregated and anonymous form. We may aggregate Usage Information associated with your Personal Data into business-related research events, which include the form of engagement and content type, topics derived from the content of the event, and date/timestamp of when the event occurred, in anonymous form. An interest event may be, for example, the downloading of a whitepaper on cloud computing, or clicking on an advertisement related to SSL certificates.

We may also share information with trusted companies that assist us in the operation of our business or provide services such as our blog and career pages. These companies are not authorized to use the Personal Data we share with them for any other purposes than those set forth in this Privacy Policy or to send you any unsolicited e-mails.

In certain situations, we may be required to disclose Personal Data: (a) to protect the legal rights, privacy or safety of Madison Logic or our employees, agents or contractors; (b) in response to lawful requests from government or by public authorities in any country in which we operate, including for national security or law enforcement requirements; (c) to permit us to pursue available remedies or limit the damages that we may sustain; or (d) as required by law, for example to comply with a subpoena, bankruptcy proceedings, or similar legal process. .

Updating Personal Data and your Data Subject Rights 

Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any Personal Data relating to you to the extent required by our participation in the EU-U.S. Privacy Shield or other applicable legal requirements.

You may also request that we verify, correct, or update Personal Data collected through the Platform. We will respond to such request within a reasonable timeframe. However, please note that we may delete certain records that contain Personal Data that you have submitted through the Platform in accordance with our routine record keeping. We are under no obligation to store Personal Data indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Data.

We will retain your Personal Data for as long as your account is active or as needed to provide the Platform. You may request that we cancel your account or request that we no longer use your Personal Data to provide the Platform. However, we may retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where your Personal Data is processed in the context of our activities in the European Union, you have the following statutory rights with regards to your Personal Data under the General Data Protection Regulation (“GDPR”):

  • you can request access to your Personal Data, including the provision of a copy of the Personal Data subject to processing (right of access according to Art. 15 GDPR);
  • you can ask us to update or correct any inadequate, incomplete or inaccurate data (right to rectification according to Art. 16 GDPR);
  • you can request erasure of your Personal Data (right to erasure according to Art. 17 GDPR);
  • you can restrict the processing of Personal Data (e.g. we may only store but not use your information while we assess your request for erasure – right to restriction according to Art. 18 GDPR);
  • where processing is based on our legitimate interests including profiling, you have the right to object to the processing (right to object according to Art. 21 (1) GDPR);
  • where we process your Personal Data for direct marketing purposes, you have the right to object to the processing at any time (right to object according to Art. 21 (2) GDPR);
  • where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (right to withdrawal according to Art. 7 (3) GDPR);
  • where processing is based on consent or on a contract, you have the right to data portability, meaning that you can ask us to provide your Personal Data in a structured, commonly used and machine-readable format for your use or transfer to another controller (right to data portability according to Art. 20 GDPR);
  • you can lodge a complaint with a supervisory authority (right to lodge a complaint according to Art. 15 no. 1 (f) GDPR).

If you wish to exercise any of the rights described above or you have any questions or concerns about how we treat your Personal Data, please contact us at http://go.madisonlogic.com/RequestMyInfo.html or by mail to 257 Park Avenue South, 5th Floor, NY, NY 10010 We will respond to your request within one month of receipt, either to provide the information or confirm completion of the act requested or, in certain circumstances, to notify you of an extension of the timeframe for response by a maximum of two further months.

Data Security Precautions & Retention

Madison Logic takes precautions to protect all Personal Data and any other information under its control from misuse, loss or alteration. Madison Logic’s security measures include industry-standard technology and equipment to help protect your information, and Madison Logic maintains security measures to allow only the appropriate personnel and contractors access to your information. Unfortunately, no system can ensure complete security, and Madison Logic disclaims any liability resulting from use of the Platform or from third-party hacking events or intrusions.

Specific retention periods are determined by reference to the type of third-party concerned, as set out below:

  • Usage Information is retained for up to 13 months from the date of collection, after which it will be de-identified and aggregated for research and analytics;
  • Personal Information from registrations is retained for up to 5 years from the last registration date; and
  • cookies expire 18 months after their last update.

Other Web Sites

The Platform may contain links to or integrations with other sites that Madison Logic does not own or operate. This includes links from Clients and partners that may use the Madison Logic logo in a co-branding agreement, or websites and web services that we work with in order to provide the Platform. Madison Logic does not control, nor is Madison Logic responsible for, these sites or services or their content, products, services, privacy policies or practices. If you submit Personal Data on a web site using the Platform, you are choosing to disclose information to both Madison Logic and the third party with whose brand the website is associated. This Privacy Policy only governs Madison Logic’s use of your Personal Data. A third party’s use of your Personal Data is governed by the third party’s privacy policy and practices, and not by this Privacy Policy.

Business Sale

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, or a sale of our significant assets, we reserve the right to include any Personal Data and other information we have collected as described in this Privacy Policy among the assets transferred as part of any transaction

Children

Madison Logic does not knowingly collect Personal Data or Usage Information from children under the age of 13 through its website (http://madisonlogic.staging.wpengine.com) or from any of our affiliates and partners. If you are under 13, please do not give us any Personal Data, and do not provide Personal Data to any website or web service without consulting your parent or guardian. If you have reason to believe that a child under the age of 13 has provided Personal Data to Madison Logic, please contact us at privacy@madisonlogic.com and we will seek to delete such Personal Data from our database.

Consent to Processing and Transfer of Information

The Platform and the servers and facilities that maintain the data we hold are operated in the United States and other countries outside of the European Union. As an international business, our use of information necessarily involves the transmission of Personal Data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be accessed, transferred to and processed in the United States. By using the Platform, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.

To protect your Personal Data in these circumstances, Madison Logic Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Madison Logic is committed to subjecting all Personal Data received from European Union (“EU”) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles, and to complying with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, including the onward transfer liability provisions (in addition to complying with its obligations pursuant to GDPR).  To learn more about the Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

Madison Logic is responsible for the processing of any Personal Data that it receives, under the Privacy Shield Framework, and subsequently, is also responsible for transfers to a third party acting as an agent on its behalf.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Madison Logic is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Madison Logic may be required to disclose Personal Data in response to lawful requests by public authorities, including for national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider free of charge at https://feedback-form.truste.com/watchdog/request. Under certain conditions (as more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

If you have any inquiries or complaints about Madison Logic’s handling of your personal data under Privacy Shield, or about our privacy practices generally, please contact us at privacy@madisonlogic.com. We will respond to your inquiry promptly. If we are unable to satisfactorily resolve any complaint relating to the Privacy Shield, or if we fail to acknowledge your complaint in a timely fashion, you can submit your complaint online at https://feedback-form.truste.com/watchdog/request, which provides an independent third-party dispute resolution service based in the United States. If neither Madison Logicnor our third-party dispute resolution resolves your complaint, you may pursue binding arbitration through the Privacy Shield Panel. To learn more about the Privacy Shield Panel, click here.

When Madison Logic receives information and then transfers it to a third-party service provider acting as an agent on Madison Logic’s behalf, Madison Logic has certain liability under the Privacy Shield if both: (i) the agent processes the information in a manner inconsistent with the Privacy Shield; and (ii) Madison Logic is responsible for the event giving rise to the damage under the Privacy Shield.

Social Media Widgets

Our website includes social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our website (collectively, the “Features” and each a “Feature”). These Features may collect information such as your Internet protocol address, the page you are visiting on our website, and may set a cookie to enable the Feature and related data collection to function properly. Features are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Blogs

Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@madisonlogic.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Changes to our Privacy Policy

Please note, we may modify information presented via the Platform and/or this Privacy Policy from time to time. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes we will provide notice on this website prior to the change becoming effective. You are encouraged to periodically revisit the Madison Logic Privacy Policy to see if it has been updated. We will always state the latest modification date of the Privacy Policy at the top of this page for your reference.

Madison Logic Services

Madison Logic acts as a data processor in the provision of its services to its Clients (“Services”) where it collects information under the direction of any one of its Clients, which may include Personal Information and Usage Information such as cookie identifiers.  We will retain Personal Data for as long as necessary to provide these Services and we may share such information with the relevant Client as set out in the Privacy Policy.

If you are a customer of a Client and would no longer like to be contacted by the Client that uses our Platform, please contact the Client that you interact with directly. Similarly, should you wish to access Personal Data or to correct, amend, or delete inaccurate data owned by a Client, you should direct your query to the Client.

Contact Us

We regularly review our compliance with this Privacy Policy. Questions, comments, and requests regarding this Privacy Policy are welcomed and should be sent by e-mail to privacy@madisonlogic.com or by mail to 257 Park Avenue South, 5th Floor, NY, NY 10010