Initiative Website Privacy Notice
Effective Date: June 11, 2018
Initiative Media, LLC (“Initiative”) respects your concerns about privacy. This Website Privacy Notice describes the types of personal information we collect about individuals on www.initiative.com (the “Site”), how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The Website Privacy Notice also describes the measures we take to safeguard the personal information, how long we retain it and how individuals can contact us about our privacy practices and to exercise their rights.
Click on one of the links below to jump to the listed section:
- Information We Obtain
- How We Use the Information We Obtain
- Information Sharing
- Data Transfers
- Your Rights and Choices
- Other Online Services and Third-Party Features
- Retention of Personal Information
- How We Protect Personal Information
- Children’s Personal Information
- Updates to Our Website Privacy Notice
- How to Contact Us
Information We Obtain
We may collect and store personal information (such as name and other contact details) that you choose to provide to us when you provide them through the Site or when you contact us. The types of personal information we collect may include:
Contact information, such as your name, e-mail address and telephone number; and
Other personal information you may submit to us, such as when you contact us.
Automated Collection of Data
When you use the Site, we may obtain certain information by automated means, such as browser cookies, device identifiers, server logs, and other technologies. The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the Site (such as the web pages you visit, links you click and features you use), the pages that led or referred you to the Site, dates and times of access to the Site, and other information about your use of the Site.
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookie technology holds information a site may need to personalize a visitor’s experience. Cookies may also be used for security purposes.
These technologies help us (1) track and understand how you use and interact with the Site; (2) measure the usability of the Site; (3) understand the effectiveness of our communications; and (4) otherwise manage and enhance the functionality of the Site.
To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. You may adjust your cookie settings at any time by clicking here. You can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.
Third-Party Web Analytics Services
We may obtain personal information about your online activities over time and across third-party websites, devices and other online services. On the Site, we use third-party online analytics services, such as those of Google Analytics. The service providers that administer these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate, for example, use of the Site and to diagnose technical issues. To learn more about Google Analytics, please visit www.google.com/analytics/learn/privacy.html.
How We Use the Information We Obtain
We may use the information we obtain on the Site to:
- provide our services to you;
- market our services to you;
- process, evaluate and respond to your requests and inquiries;
- operate, evaluate and improve our business (including developing new services; enhancing and improving our services; analyzing our services; managing our communications; performing data analytics and market research; and performing accounting, auditing and other internal functions);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Website Privacy Notice and Initiative’s Terms and Conditions.
As required by applicable law, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and, as permitted by law, pursue our legitimate interests (such as managing the Site, performing data analytics, and operating, evaluating and improving our business). We also may use the information we obtain in other ways for which we provide specific notice at the time of collection or otherwise with your consent.
We do not disclose personal information we obtain about you, except as described in this Website Privacy Notice. We may share your personal information with our (1) Initiative-related entities and (2) service providers who perform services on our behalf, such as hosting this Site or data analytics, for the purposes described in this Website Privacy Notice. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); or (7) otherwise with your consent.
We may transfer the personal information we collect about you to recipients (including our subsidiaries and affiliates, and third party service providers) in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Website Privacy Notice.
Your Rights and Choices
We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, update or correct your information, limit the communications you receive from us, or submit a request, please contact us as specified in the How to Contact Us section of this Website Privacy Notice. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by applicable law, you may (1) request access to the personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict the information; or (3) exercise your right to data portability, by contacting us as indicated below. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
Other Online Services and Third-Party Features
The Site may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets and plug-ins (e.g., LinkedIn, Instagram, Facebook and Twitter buttons). These services and websites may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these third parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, Initiative is not responsible for these third parties’ information practices.
Retention of Personal Information
To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Website Privacy Notice, or (2) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Children’s Personal Information
The Site is designed for a general audience and is not directed to children under the age of 13. Initiative does not knowingly collect or solicit personal information from children under the age of 13 through the Site. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Website Privacy Notice.
Updates to Our Website Privacy Notice
This Website Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.
How to Contact Us
To update your preferences, update or correct your information, submit a request, ask us questions about this Website Privacy Notice, or exercise other applicable privacy rights, please contact us as follows:
Residents of the U.S. may contact us by email at [email protected] or write to us at:
Attn: Communications Director
100 West 33rd Street, 4th Floor
New York, NY 10001
Our GDPR Data Protection Officer is Orla Isaacson
[email protected] for queries regarding UK data processing
[email protected] for queries regarding EUdata processing
Residents of China may contact us by email at [email protected] or write to us at:
Attn: Naomi Michaels, Head of Marketing and Communications
D River Valley Road #02-01
Clarke Quay, Singapore, 179023