Effective date: August 3, 2018
The Midroll, LLC (“Midroll”, “we”, “us”, “our”), which is operated by The E.W. Scripps Company, is committed to fulfilling our responsibilities under the European Union’s General Data Protection Regulation (“GDPR”) in relation to the collection, retention, use, and other processing of personal data that is obtained when EU data subjects visit and interact with our website, email newsletter, and other digital platforms and services (together, the “Service”). This Privacy Notice sets forth how we process EU personal data in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing).
This Privacy Notice covers:
- Personal Data We Collect
- How and Why We Use Your Personal Data
- How We May Share Your Personal Data
- How We Protect Your Personal Data
- How Long We Retain Your Personal Data
- Personal Data Transfers
- Your Rights and Choices
- How to Contact Us
Personal Data We Collect
We may collect and process the following information when you interact with the Service.
- Contact data. You may provide us with your contact details, such as name and email address.
- Account Information. In addition to contact data, when creating an account, you may provide us with additional information about yourself including your company name.
- Authentication Data. To verify the identity of registered users we may collect a user name, password, and other similar authentication information.
- Device Information. We may obtain information about devices that access our Service, including the type of device, its operating system, device settings, unique device identifiers, and crash data.
- Job Application Information. If you apply for a job through our Careers page, we or our vendor may collect your name, e-mail address, physical address, phone number, and CV.
- Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as customer support inquiries or surveys.
How and Why We Use Your Personal Data
We may process personal data to:
- Transact with you, respond to your comments, questions and requests, provide customer service, send you informational notices, and contact you if we need to obtain or provide additional information;
- Process job applications received through our Careers page;
- Facilitate, manage, personalize, and improve our customer and partner relationships;
- Prevent and address fraud, breach of policies or terms, and threats or harm;
- Ensure the security and integrity of the personal data we process; and
- Comply with applicable legal requirements.
Our processing of such personal data is carried out pursuant to the following legal bases:
- You have consented to the use of your personal data. When you consent, you can change your mind at any time.
- The processing is necessary for us to provide you with the services and products you request, or to respond to your inquiries.
- We have a legal obligation to process your personal data, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- To protect your vital interests, or those of others.
- We have a legitimate interest in using your personal data. In particular, we have a legitimate interest in the following cases:
- To analyze and improve the safety and security of our Service. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
- To maintain and improve the Service.
- To operate the Service and provide you with certain tailored advertising and communications to develop and promote our business.
- To anonymize personal data and subsequently use the anonymized information.
If we make a material change to how we process your personal data, we will notify you and may also modify this Privacy Notice.
How We May Share Your Personal Data
We may share your personal data:
- With our affiliates or business partners when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the website.
- To our agents, vendors, consultants, marketing service providers, and other service providers who perform functions on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other websites, and send marketing and other communications on our behalf.
- To abide by applicable law or protect rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.
- If we are involved in a reorganization, merger, acquisition, or sale of some or all of our assets.
Please note that in certain situations Midroll may be obligated to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We utilize online identification technologies—such as cookies, web beacons, or pixels—in accordance with applicable law and requirements. “Cookies” are small text files placed on your hard drive when you visit a website; they store information which is sent back to our servers or those of third parties. As described in more detail below, we use such technologies to:
- Recognize new or past customers;
- Store your password if you are registered on our website;
- Improve our website and to better understand your visits;
- Serve you with interest-based or targeted advertising;
- Observe your behaviors and browsing activities over time across multiple websites or other platforms; and to
- Better understand the interests of our customers and our website visitors.
Different types of cookies may be used for specific purposes, for example:
- Functional cookies and cookies from third parties may be used for analysis and marketing purposes. Functional cookies enable certain parts of the website to work properly and retain user preferences.
- Analysis cookies may collect information on how visitors use a website, the content and products that website users view most frequently, and the effectiveness of third-party advertising.
- Advertising cookies assist in delivering ads to relevant audiences. This may include, for example, placing ads at the top of search results.
Cookies are either “session” cookies which are deleted when you end your browser session, or “persistent,” which remain until you delete them or the party who served the cookie removes it. Further details concerning the cookies we use on our websites are available in the table included at the bottom of this section.
We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Notice. Similarly, the third parties who serve cookies on our website may link your name or email address to other information they collect.
|Preferences||Cookies that allow our website to remember information that alters the way the website behaves or appears on your screen. For example, we may provide you with local ads based on your region. Loss of information stored in these cookies may make the website experience less functional but should not prevent the website from working.|
|Processes||Cookies that are fundamental to functional operation of the website that deliver services that our visitors expect, such as navigating web pages or accessing secure areas on our website. The website will not function without these cookies.|
|Advertising||Cookies used to make advertising more relevant for visitors. Our partners may also use a cookie to determine whether we’ve shown an ad and how it performed or provide us with information about how you interact with ads.|
|Session State||Cookies that collect information about how visitors interact with the website. This may include the pages users visit most often and whether users get error messages from certain pages. We use these cookies to help us improve our Services. Blocking or deleting these cookies will not render the website unusable.|
|Analytics||Cookies that help us assess how well our website performs and how items such as plugins perform in different areas on the website. These cookies are also used to understand, improve, and research products, features, and services.|
How We Protect Your Personal Data
We maintain appropriate technical and organizational safeguards designed to help protect personal data from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. Although we use reasonable efforts to safeguard personal data, we cannot guarantee the security of your information obtained through the Service.
How Long We Retain Your Personal Data
We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.
Personal Data Transfers
We will obtain appropriate consent from EU data subjects prior to transferring their personal data out of the EU to a country that has not been deemed by the European Commission to provide an adequate level of personal data protection. Please contact us if you have questions regarding our cross-border data transfer activities.
Your Rights and Choices
The GDPR provides EU data subjects with certain rights regarding their personal data. Subject to certain conditions, you may ask Midroll to take the following actions in relation to your personal data that we hold:
- Provide you with information about our processing of your personal data and give you access to your personal data.
- Update or correct inaccuracies in your personal data.
- Delete your personal data.
- Transfer a machine-readable copy of your personal data to you or a third party of your choice.
- Restrict the processing of your personal data.
- Object to our processing of your personal data for direct marketing purposes.
- Object to reliance on our legitimate interests as the basis for processing of your personal data.
You can submit these requests by email to email@example.com or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at firstname.lastname@example.org or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.
How to Contact Us
Midroll can be contacted via e-mail sent to email@example.com or at the following address:
The E.W. Scripps Company
Attention: Data Protection Inquiry
312 Walnut St, Suite 2800
Cincinnati, OH 45202
United States of America