Ciceron Privacy Notice for EU Residents

Prepared by Kraig Larson, Rev 1, June 6, 2018

Ciceron Inc. (“Ciceron,” “we” or “us”) owns, operates, or provides access to Ciceron.com and Ciceron’s mobile applications, email newsletters, and other sites, digital platforms and interactive services (“Services”). This Privacy Notice for EU Residents (“Notice”) applies only to the Services and does not govern the separate websites, applications, newsletters, platforms and services of Ciceron clients or of any third parties that may link to or be linked to from the Services. This Privacy Notice governs our privacy practices in handling the information we collect about individuals in the EU who use our Services (“you” or “your”). Terms that are not defined in this Notice have the same definitions as in Ciceron’s Terms of Use. Ciceron processes personal data under this Privacy Notice as a data controller. The Contact Details of Ciceron are listed at the end of this Notice. This Notice may be changed if there is a change in the way Ciceron processes personal data or if there is a change in applicable law. We will notify users of changes that are deemed material under applicable law by updating the date of this Notice and providing other information as required.

Last modified: June 6, 2018.

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Categories of Data Obtained Directly from You

Ciceron obtains personal data from you including your name, email address, postal address, telephone number, and payment card information. We collect this information when you:

  • Register for a Ciceron account or any Ciceron email newsletter.
  • Email, text or otherwise share an article from any of the Services.
  • Contact us for information or ask a question.
  • Register for a Ciceron event or any contest we sponsor.
  • Apply for a job or internship at Ciceron
  • Otherwise volunteer information to us or respond to a request for information through any of our Services.
  • If you choose to participate in a survey, we may ask you to provide your date of birth, gender, education level, information about your employment, income level and other information.

Information Obtained Automatically Through Technology

You can find our Statement Regarding Cookies and Other Tracking Technologies here.

Depending on which Services you use and how you access them, the information collected automatically through technology, such as access logs, cookies, pixels and other tracking technologies, may include:

  • Internet Protocol Address (IP address)
  • The domain name of your Internet Service Provider
  • The website, application, platform or service you visited before and after visiting our Services.
  • Information about your computer or mobile device, and their browser, operating system, settings and software.
  • Unique device identifiers on your mobile device, including as applicable the Apple or Google advertising identifiers.
  • Your approximate geographic location (derived from requested header information, such as your IP address) and/or more precise location information if you have given Ciceron consent to receive this information for a Ciceron application on your mobile device.
  • The dates, times, duration and frequency of your interactions with our Services, search terms, the media files you download, interact with or share, favorites you select, and your navigation path through our Services.
  • Listening data, including information about your interactions with Ciceron podcasts and other media files, such as time and date stamps for when a file is downloaded and when playback of a particular segment starts, stops, is skipped or paused.
  • Information about your interactions with our email messages.
  • Any errors you encountered during your use of the Services.
  • If you sign in to the Services from a social networking service (“SNS”), we receive your email address and certain profile information from such SNS in accordance with its privacy policy and your SNS account privacy settings.

Information Not Obtained Directly from You

The Services use third-party analytics, cookie data collection and linking services (collectively “Analytics Services”), including Google Universal Analytics, Google Analytics Demographics and Interest Reporting and DoubleClick for Publishers. These Analytics Services may use cookies, pixel tags, and other tracking and storage technologies to collect or receive information (not including your name or the email address you register with Ciceron) from the Services and elsewhere on the Internet and use that information to analyze and measure Ciceron’s audience and target and evaluate the effectiveness of the Services. For example, Ciceron and Analytics Services may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve messages based on your past interactions with our Services and other websites or services. In addition, we may use analytics data, including but not limited to, geographic, demographic, and interest reporting information to recognize and understand user preferences, make improvements, and for other operational purposes.

Purposes for Processing of Personal Data

Ciceron processes your data in order to:

  • Manage, administer, promote, analyze and improve the Services and our communications, including measuring and analyzing user traffic and usage patterns.
  • Respond to your questions or messages and fulfill your requests for services.
  • Customize the content you see and hear on our Services.
  • Customize the messages you see and hear on our Services and on third-party services you may use or visit.
  • Offer you access to Ciceron events.
  • Process applications for jobs, internships , and other positions at Ciceron.
  • Manage contests, contact you for an online survey, or for editorial purposes.
  • Recognize you as a returning user as you access our Services using different computers, devices and browsers and to save and “remember” your registration information, settings and preferences for later visits.
  • Send you email newsletters and marketing, and other communications from Ciceron.
  • To understand whether and when you read our email messages and click on links in those messages.
  • Analyze personal preferences or interests to provide personalized content and messages from Ciceron and to control the sequence and frequency of those messages.
  • Generate aggregate or other information that does not directly identify you as an individual or the devices you use to access our Services, and use and share that information for Ciceron’s purposes.
  • To prevent potentially prohibited or illegal activities, comply with applicable laws, and enforce our Terms of Use and other legal rights.
  • We also may use the information collected from you in other ways, and for other purposes, that are described to you at the point of collection or for which we otherwise have obtained your consent.

Sharing Your Personal Data

Ciceron may share your personal data with the following categories of recipients:

  • Ciceron’s authorized service providers to provide services on our behalf.
  • Ciceron’s authorized third-party applications to provide certain Services to you on the third-party applications.
  • Ciceron’s analytics partners such as Google Universal Analytics, Google Analytics Demographics and Interest Reporting, DoubleClick for Publishers and others.
  • If we sell a Service or in the unlikely event of bankruptcy.
  • With public authorities when required by law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with legal or regulatory obligations.
  • With other parties when necessary to enforce our Terms of Use, to protect the vital interests of our users or other natural persons, Ciceron, or when required by law.
  • With persons we contact on your behalf when you choose to email, text, or otherwise share an article or other content through the Services.
  • With social networking services, if you choose to share articles or other content with your friends and followers on the social networking service.
  • With other parties if the information is anonymous and aggregate.
  • With other parties if we have disclosed such sharing to you at the time of collection of the information or if we otherwise have your consent.

Lawful Basis for the Processing of Personal Data

Ciceron is required to demonstrate a lawful basis for the processing of personal data. Ciceron relies on legitimate interest to process data for the following purposes:

  • Data analytics
  • Managing user accounts
  • Operating, modifying and improving the Services
  • Identifying usage trends
  • Customizing content and user experience
  • Web hosting
  • Direct marketing
  • Fraud prevention
  • Network and information systems security
  • To determine the effectiveness of promotional campaigns and messaging
  • To serve promotional messages based on user behavior and preferences.
  • Responding to user questions and requests for information
  • Comply with laws and regulations and enforce Ciceron’s Terms of Use and other legal rights.

Consent: We process personal data based on your consent to send personalized messages from Ciceron, to collect precise location information and to send promotional emails. If you do not consent to the processing, you may not be able to access all of our Services. If you do grant consent, you can withdraw your consent at any time by controlling your cookies, unsubscribing from emails and as described in “Your Rights” below. Please note that all processing of your personal data will cease once you have withdrawn consent but this will not affect any personal data that has already been processed.

Retention

Your personal data is retained no longer than is reasonably necessary to perform the processing described in this Notice and in case of any legal claims or complaints, or as required by law.

Your Rights

Subject to exemptions under applicable law (which may include, depending on the circumstances, U.S. law protecting the rights to free speech and free press or EU law protecting the rights to freedom of expression or information, including processing for journalistic purposes), you have the following rights with respect to your personal data:

  • To request a copy of your personal data which Ciceron holds;
  • To request that Ciceron provide you access to and/or rectify personal data that is inaccurate or out of date;
  • To request erasure of your personal data where it is no longer necessary for Ciceron to retain it;
  • If you have consented to processing, the right to withdraw consent at any time;
  • To request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable. This right of portability only applies where the processing is based on consent or is necessary for the performance of a contract and if Ciceron processes the data by automated means;
  • To request a restriction on further processing where applicable;
  • The right to object to processing if the processing is based on legitimate interest, is for direct marketing, or is for scientific/historical research and statistics;
  • To lodge a complaint with a supervisory authority.

You may exercise these rights by contacting Ciceron at privacy@ciceron.com, providing the email address you used to register with Ciceron, and stating your specific request in writing. Ciceron reserves the right to verify your identity and confirm your right to the information. The following options are also available:

  • For information on opt-out tools for advertising messages click here.
  • To withdraw consent for collection of precise device location, you may access the privacy settings of your mobile device and/or the settings of the Ciceron mobile application.
  • To withdraw consent to marketing emails or email newsletters, click the “unsubscribe” link on the email. You may also change your newsletter preferences by contacting us. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Terms of Use or this Notice).
  • To correct or update your registration information, you may contact us using the information below.
  • To prevent your data from being used by Google Analytics, click here for the Google Universal Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout. To learn more about how Google uses data, visit google.com/policies/privacy/partners/.

 

How can I control cookies?

You have the right to decide whether to accept or reject cookies.

Website Cookie Preference Tool: You can exercise your Website cookie preferences by visiting the TRUSTe preference center by clicking this link: http://preferences-mgr.truste.com/.

Browser Controls: You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Websites though your access to some functionality and areas of our Websites may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

Disabling Most Interest Based Advertising: Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of Interest Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system.

Do Not Track: Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Websites do not currently process or respond to “DNT” signals. Ciceron takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. To learn more about “DNT”, please visit All About Do Not Track.

Transfer of Data Abroad

Because Ciceron operates the Services from the US, your personal data may be transferred to the US and/or to countries or territories outside the EEA or Switzerland not recognized by the European Commission as ensuring an adequate level of protection pursuant to the GDPR. Where required, data transfers will be made subject to the terms of the applicable EU Standard Contractual Clauses or with your consent. Ciceron will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Privacy Notice in respect of such transfer.

Security

Ciceron employs physical, technical and organizational safeguards to ensure an appropriate level of security for personal data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and security for the rights and freedoms of natural persons,

Automated Decision Making and Analysis

Ciceron and its data analytics vendors analyze user interactions with the Services to deliver personalized content to users and to serve personalized messages. This includes tracking user preferences with respect to listening data, websites visited, and search terms in order to derive a user’s interests and preferences. The consequences of such processing for the data subject are that the data subject receives content that may be of interest to him or her, as well as email, online and in-app messages from Ciceron that are geared towards the interests and preferences of the data subject.

Age Limits

You must be at least 18 years of age to submit any Personal Data on or through the Services, create a public profile, or participate in any online contests. If your child is under age 16 and has provided personal data to the Services, please contact us at privacy@ciceron.com for deletion of the data.

Further Processing

If Ciceron plans to use personal data for a new purpose, it will update this Notice and communicate the changes to individuals before starting any new processing.

Contact Details

Data Protection Officer
Kraig Larson
Ciceron
126 North Third Street, Suite 200
Minneapolis, MN 55401
privacy@ciceron.com

Data Controller
Ciceron
126 North Third Street, Suite 200
Minneapolis, MN 55401
privacy@ciceron.com