Website Privacy Policy

Introduction

This Website Privacy Policy (“Privacy Policy”) only applies to the information Konduit.me collects through our corporate website, konduit.me and any other websites (“Sites”) owned and operated by Konduit.me, Inc. and its subsidiaries and affiliates (collectively, “Konduit.me”) effective April 1, 2018. In this policy, we provide transparency in our personal data collection in terms of how we use the personal data, the reasons we share personal data, and how you can access and control your personal data. If you are a consumer or business partner and would like to understand our privacy practices in connection with services we provide to our clients, please click here to see our Platform Services Privacy Policy.

To go direct to our opt-out, click here. 

Data Collection

When you visit our Sites and engage with the features offered on the Sites, we may collect personal data from you in order to provide a better and more relevant experience to those individuals visiting our website.

Specifically, the information we collect automatically may include information like your IP address, device type, domain, referring website address, browser type and language and other technical information.  We may also collect information about how your device has interacted with our Online Properties, including the pages accessed, search keywords and links clicked. We refer to all of this information as “Digital Identifiers”.

We may collect the subsequent information about you both automatically and through the data you voluntarily provide.

Information is obtained from you voluntarily on some pages of the Sites. For instance, you may choose to provide personal data about you to Konduit.me for a specific purpose, such as when submitting a request for information, submitting a specific question to Konduit.me about our services or related to your privacy, requesting that Konduit.me contact you or signing up to receive emails from Konduit.me about our products and services. Furthermore, if you enter into a business relationship with Konduit.me, we may need you to provide us with personal data for administrative purposes, such as maintaining account information, preparing invoices and issuing payment.

If you register for a platform client account, the information we collect may include contact information (such as name, address telephone number and/or email address). It may also include professional information, such as job title, department or role, and the nature of an individual’s access to the account.

Information is also collected automatically when you use our Sites. Konduit.me or our third-party partners may automatically obtain certain information from an individual’s media device. In some countries, including countries in the European Union (“EU”), this information may be considered personal data under applicable data protection laws. Information we collect automatically may include, but is not limited to, digital identifiers such as IP address, operating system type and version, browser type and version, cookie ID, browser activities on the Sites, and other information about the individual’s system and connection and how the individual interacts with the Sites. We and our third-party partners may collect this information as a part of log files and through the use of cookies. To learn more about our use of cookies, please see our Website Cookie Policy.

Information is also collected automatically when you use Social Media Plugins. Our website may include plugins from social networks or other third parties. An example of a plugin is the link to Konduit.me’s Twitter feed or LinkedIn page. Regardless of your interaction, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plugin. This information may include personal data and digital identifiers such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. Cookies may be placed when loading, using or clicking the plugins. These cookies may contain a unique identifier the social network or third party assigns to you for use in associating information collected about your browser, so they can deliver interest-based advertising to you. The loading, functionality and your use of the plugins are governed by the privacy policy and terms of the party that provided the plugin. To learn more about the information collected by social media plugins and opt-out of their data collection, please see our Website Cookie Policy.

Data Use

Konduit.me utilizes the personal data collected both voluntarily and automatically for the following functions:

  • To communicate with and respond to your inquiries, to conduct research about use of our platform and services; to fulfill your requests for products and services; to help offer you other products, services or offerings that may be of interest to you; and to provide internal and external reporting
  • To send marketing and promotional communications, using personal data such as you email address to send commercial or marketing messages about our products and services, which you may, at any time elect to opt-out of by following the opt-out instructions included with the email you receive
  • To send administrative information for purposes such as notifying you of important changes to the Services, terms and conditions, policies, or for customer service purposes
  • To engage in and process transactions such as billing
  • To administer and manage accounts on Konduit.me's platform and to provide customer support or other requested services or information about our services
  • To select relevant content and to help enhance the quality of the Sites and our services and to ensure that content on the Sites is presented in the most effective manner for your media device
  • For legal purposes deemed to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • For business purposes such as data analysis, audits, identifying usage trends, evaluating the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships
Data Access and Information Sharing

In the process of providing our Services, we may transfer information across borders from your country or jurisdiction. With the exception of data transfers from the EU and Switzerland, by providing Konduit.me with you information, you hereby consent to the transfer of information.

This information will be provided to trusted partners who work on behalf of or with Konduit.me under confidentiality agreements. These companies may use your information to help Konduit.me fulfill a transaction you requested or communicate with you about offers from Konduit.me. We may share your information legally and ethically with the following:

  • Affiliates in order to fulfil legal/contractual obligations to you.
  • Vendors, consultants, and other service providers, who are our third-party service providers, vendors, contractors, or agents who perform functions required for the operation of the business (Examples include: to provide data storage and processing services, payment processing, technical support for our platform and Sites, and fraud prevention)
  • Business Transfers, with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
  • Social Media Plugins are utilized on our Sites and individuals may choose to share information on message boards, chat, profile pages and blogs and other services that allow visitors to post information and materials (including, without limitation, our social media pages). Please note that any information posted or disclosed through these services and forums will become public information, and may be available to users of the Sites and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, on the Sites.
  • For legal purposes: We may share your information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Data Retention

The amount of time that we retain information we collect on each of our systems varies in length based on the type of data collected. However, personal data is only retained by us so long as necessary to carry out the purposes outlined in this Privacy Policy.

Standard practice is that we retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and where we have ongoing legitimate business needs to do so. For example, we retain personal information in order to comply with applicable legal, tax or accounting requirements and to enforce our agreements or comply with our legal obligations, unless a longer retention period is required or permitted by law.

Any personal data voluntarily provided to us via email communication or through our corporate website is maintained no longer than is necessary to carry out the purposes described in this Privacy Policy.

Personal Decisions and Rights

You have the right to opting out of receiving electronic communications from us.

To opt out of marketing-related emails from us on a going-forward basis, please contacting us at privacy@konduit.me or select the opt-out link within email messages that you receive from us. However, keep in mind if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to our services from time to time.

You have the right to request access to or that we amend, update, or delete information we’ve collected in accordance with this Privacy Policy at any time.

We reserve the right to charge a small fee for access and disclosure of your personal data where permitted under applicable law, which will be communicated to you. To exercise this right email privacy@konduit.me.

You have the right to withdraw your consent to our collection and processing of your personal data, as outlined in in accordance with this Privacy Policy, at any time. 

You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing basis other than consent. To exercise this right email privacy@konduit.me.

If you are a resident of the EU/ EEA, …

You also have the right to object to processing of your personal data collected, restrict processing of your personal data, or request portability of your personal data, in each case as collected in accordance with this Privacy Policy. To exercise these rights email privacy@konduit.me.

Data Protections and Security

Consistent with industry standards and applicable international law, Konduit.me has established appropriate technical and organizational measures to secure and protect your personal data. Konduit.me will aim to prevent unauthorized access to, disclosure, alteration or misuse of your information. While Konduit.me cannot guarantee that your data will never be disclosed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties that violate applicable law or Konduit.me’s policies), we will make every effort possible to protect and uphold your privacy rights. All data stored on Konduit.me’s servers is treated as confidential. Our employees have appropriate and limited access and know such data is confidential.

Cross-Border Data Transfers

Konduit.me is headquartered in the United States. With operations, entities, and service providers in the United States and throughout the world, we and our service providers may transfer your information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take measures to ensure that your information receives an appropriate level of protection in the jurisdictions in which we process it. If you are located in the EU/EEA, we provide adequate protection for the transfer of personal data to countries outside of the EU/ EEA through a series of intercompany agreements based on the Standard Contractual Clauses authorized under the General Data Protection Regulation (EU) 2016/679.

Children's Privacy

Our Services are not developed or intended for individuals that are deemed to be children under applicable data protection or privacy laws. Under the California Consumer Privacy Act (CCPA), there is a mandatory opt-in before the sale of information from children under the age of 16. However, in compliance with the Children’s Online Privacy Protection Rule (COPPA), we do not knowingly collect information from such individuals under the age of 13 as a standard, and we request that such individuals do not provide information to us through any of the Sites’ voluntary channels such as contact forms.

Lawful Bases for Processing Your Information

For all users, we will only collect and process personal data about you where we have a lawful basis to do so. Lawful bases include consent (where you have given consent to such processing), processing is necessary for the performance of a contract, processing is necessary for compliance with a legal obligation and processing based on “legitimate interests”.

We may process your personal data for the purposes of our legitimate interests, provided that such processing shall not override your rights and freedoms. For example, we may process your personal data to:

  1. Improve the quality and content of the Sites, including the performance of the Sites on various media devices
  2. Perform analytics on the performance of our Sites, usage trends and the services provided on the Sites
  3. To evaluate and improve our products, services, marketing, and client relationships
GDPR

GDPR is a new set of rules in the European Union designed to give residents of the EU more control over their Personal Data. It’s goal is to ensure that citizens and businesses in the European Union can fully benefit from the modern digital economy. According to the text, the “Regulation protects fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data.” Generally, it applies to the Personal Data of EU residents and the companies that handle it. Refer to articles 1-3 of the GDPR to determine whether it applies to you.

If GDPR applies to you, you can find the complete list of data subject rights in Chapter 3 of the GDPR, or click below for a summary:

  1. Right of Access – You have the right to obtain information from the controller or processor (us) such as the purposes of processing, categories of personal data concerned, recipients of the data, how long it may be stored, and notification of the remaining rights outlined here.
  2. Right to Rectification – The right to rectification concerns the ability to correct any inaccurate data concerning the data subject. The data that we collect, such as your IP Address, is not technically correctable, so we request that you exercise your right to erasure instead.
  3. Right to Erasure – This is also known as the right to be forgotten. If you request to be forgotten, your old ID will be disassociated from you and any information we have on that ID will be deleted in 14 days.
  4. Right to Data Portability – You have the right to receive any personal data we have in a commonly used and machine-readable format, though we are unaware of any other services which could utilize the information productively.
CCPA

The California Consumer Privacy Act (CCPA) of 2018 is a bill passed by the state of California to amend Part 4 of Division 3 of The Civil Code of the State of California. Generally, it grants the residents of California with more rights and protections for their personal data. Some of these core rights include:

  1. Right to Transparency – You have the right to know what personal information is being collected about you, to know what we are doing with your information and who we are sharing it with, and to know the business or commercial purpose of the data being collected. This includes the categories of third parties with whom your data is shared and the categories of sources of information from whom your data was acquired. All of this information is outlined in this Privacy Policy.
  2. Right of Access – You have the right to obtain information from the controller or processor (us) such as the purposes of processing, categories of personal data concerned, recipients of the data, how long it may be stored, and notification of the remaining rights outlined here.
  3. Right of Refusal – You have the right to say no to the sale of your information and withdraw your consent at anytime.
  4. Right to Erasure – This is also known as the right to be forgotten. You have the right to delete any personal data you have posted.
  5. Right to Security – Companies have a legal responsibility to protect your personal information and to have appropriate security measures in place. If a company is careless of negligent in protecting your data, you have the right to sue companies who collected your data, where that data was stolen or disclosed pursuant to an unauthorized data breach.
  6. Right to Equal Service and Price – You have the right to receive the same quality of service and the same price regardless of whether or not you choose to exercise your privacy rights.
Liability

If Konduit.me has legally transmitted your Personal Data to a third party, Konduit.me shall not be liable for any unlawful processing or unlawful use by that third party.

Under no circumstances does Konduit.me accept responsibility for any direct or indirect damage resulting from faulty or unlawful use of the Personal Data by a third party. Konduit.me is in any case only liable for the damage caused by Processing of Personal Data if it did not comply with its specific legal obligations. Konduit.me shall in no event be liable for any special, incidental, indirect or consequential losses or damages.

Contact Us

If you have any questions, complaints or concerns about this Website Privacy Policy or its implementation, you may contact us at this email address:  privacy@konduit.me, or you can send correspondence to the following address:

In the United States:

Privacy

Konduit.me

3700 O’Donnell Street, Suite 200

Baltimore, MD  21224

Please contact us first to address any questions or concerns you may have related to our privacy policy. If contacting us does not resolve your complaint and it is related to information collected about you in the European Union or European Economic Area, please contact the applicable EU Data Protection Authority.

Changes to this Privacy Policy and Additional Information

Konduit.me reserves the right to update, modify, add or delete provisions of this Website Privacy Policy from time to time. As a result, you should review this Privacy Policy periodically. Appropriate notice will be given when relevant and significant updates are made to Konduit.me’s information practices. You may be provided other privacy-related information in connection with your use of offerings from our Sites, as well as for special features and services not described in this Privacy Policy that may be introduced in the future.

Introduction

This Website Cookie Policy (the “Policy”) provides detailed information about the different types of cookies Konduit.me may set on your device (computer, tablet, etc.) when you visit Kondui.me’s corporate website at konduit.me and any other websites (“Sites”) owned and operated by Konduit.me, Inc. and its subsidiaries and affiliates (collectively, “Konduit.me”) effective January 1, 2019.

Some cookies that we use on our Site will collect information that relates to an identifiable individual. Any information that we collect via those cookies will be used in accordance with our Corporate Website Privacy Policy.

As outlined in our Website Privacy Policy, Konduit.me uses cookies when you visit our Sites to perform certain functions that are required to insure that the Sites work and we remember your preferences. We also use some social media plug-ins on the Sites that use cookies.

What is a cookie?

A cookie is a small file of letters and numbers that we store on the web browser of media device (computer, tablet, etc.). Unless you have adjusted your browser setting so that it will refuse cookies, or implemented our opt-out cookie  on your browser, our system will issue cookies when a client that uses our services sends us a request notifying us that you are viewing their media, or if you visit our corporate website. Type of cookies used on our Sites include:

 

  • Persistent cookies that help us recognize your browser as one we’ve seen before, so it’s easier for us to determine the most relevant advertising to deliver to you. When we see your browser for the first time, your browser receives a persistent cookie that remains on your browser and allows us to recognize it the next time we receive a request from that same browser.
  • Session cookies that only last for as long as the session (usually the current visit to a website or a browser session). Unlike persistent cookies, when you close your web browser, session cookies are deleted.
Cookie Usage

The sections below detail the cookies that Konduit.me uses when you visit the Sites and explain the cookie type, use and lifespan.

  • Essential Cookies are cookies whose function is essential to making the Sites work. These types of cookies enable you to move around the Sites and use their features. For example, we may use cookies to authenticate and record a platform client login, manage platform client sessions, or adjust settings and functionality on the Sites. Without these cookies, we may not be able to provide the services that are necessary for you to be able to use the Sites, such as signing into your platform client account.
  • Preference Cookies collect information about your choices and preferences. These cookies allow us to remember language or other local settings and customize the Sites accordingly. For example, we may store settings and preferences of our logged in platform clients.
  • Social Media Cookies are found on some of the pages on the Sites and contain tools or applications that are linked to third-party social media service providers such as Facebook, Twitter, and LinkedIn. The social media service provider may set its own cookies on your computer or device through these tools or applications. You should check the social media service provider’s website for further details about how they use cookies.

Cookie Name

Details

Facebook Social Plugins

Enables visitors to engage with us via Facebook and show visitors relevant ads and personalized content on Facebook. To learn more about Facebook’s practices and to opt out, please visit:

https://www.facebook.com/help/443483272359009 and

https://www.facebook.com/help/247395082112892

Twitter Button

Enables visitors to engage with us via Twitter and show visitors relevant ads and personalized content on Twitter. To learn more about Twitter’s practices and to opt out, please visit https://twitter.com/privacy?lang=en and select “Do Not Track” in certain browser settings.

LinkedIn Widgets

Enables visitors to engage with us via LinkedIn and show visitors relevant ads and personalized content on LinkedIn. To learn more about LinkedIn’s practices and to opt out, please visit:

https://www.linkedin.com/legal/privacy-policy and

https://www.linkedin.com/settings/?tab=account&modal=nsettings-enhanced-advertising


Analytics Cookies collect information about how people are using the Sites, for example which pages are visited the most often, how visitors move from one webpage to another, and whether visitors experience any difficulty using the Sites. Overall, these cookies provide us with analytical information about how the Sites are performing and how we can improve it, and in some instances, whether our advertising is effective or not.

Cookie Name

Details

Google Analytics

We use Google Analytics cookies to collect aggregate statistical data about how visitors use the Sites so that we can improve the user experience and serve up the content we believe our visitors will find most useful. Google Analytics cookies store information such as what pages users visit, how long they are on the Sites, how they arrived at the Sites, and what they click on when on the Sites.

 

To learn more about Google’s practices and to opt out, please visit http://www.google.com/policies/privacy/partners/, https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage, and https://tools.google.com/dlpage/gaoptout.

 

The following cookies may be used in connection with Google Analytics:

[_ga] Used to distinguish users and sessions.

[_gid] Used to determine users and sessions.

[_gat] Used to throttle request rate.


Personal Decisions and Rights

You have the right to exercise your choice about whether to accept or reject cookies. You can exercise your cookie preferences by following the opt-out  instructions below. Please be aware that if cookies are disabled, some of the Sites features may not operate as intended.

In addition, you can block or refuse to accept cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the 'Help' option in your internet browser for more details.

For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/index.html.

Changes to this Cookie Policy and Additional Information

Konduit.me reserves the right to update this Website Cookie Policy from time to time to allow for changes to the cookies we use for business and legal reasons. As a result, you should review this Cookie Policy periodically. Appropriate notice will be given when relevant and significant updates are made to Konduit.me’s information practices. If you have any questions, please contact us by email at privacy@konduit.me, or write to us at the following address:

In the United States:

Privacy

Konduit.me

3700 O’Donnell Street, Suite 200

Baltimore, MD 21224