Prepared by Kraig Larson, Rev 1, June 6, 2018
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.
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:
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:
Ciceron processes your data in order to:
Ciceron may share your personal data with the following categories of recipients:
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:
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 Please note that all processing of your personal data will cease once you have withdrawn consent but this will not affect any personal data that has already been processed.
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.
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:
You may exercise these rights by contacting Ciceron at firstname.lastname@example.org, 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:
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/.
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.
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.
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,
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.
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 email@example.com for deletion of the data.
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.
Data Protection Officer
126 North Third Street, Suite 200
Minneapolis, MN 55401
126 North Third Street, Suite 200
Minneapolis, MN 55401