INFORMATION ABOUT ALL MSG VISITORS
MSG may collect certain information from and about its users in several ways – directly from you, from our Web server logs, and with cookies or other forms of passive data gathering.
User-Supplied Information: There are several areas in the Website where we collect personal information from you on a voluntary basis. Personal information is information about you that is personally identifiable that is not otherwise publicly available, such as your name, address, e-mail address, mailing address or phone numbers. We may collect this information at the following times: (i) when you register to receive communications from this Website (ii) when you seek information about or purchase products offered through this Website; (iii) when you enter promotions or sweepstakes offered by this Website; and (iv) when you provide personal information to us through feedback, survey, or other forms hosted on this Website.
Third Parties: We may receive tracking information about you from third parties (such as age, gender and interests) used primarily to enhance your experience using the website and its services.
Server Log Information: When you visit an Internet Website, you disclose certain information about yourself, such as your Internet Protocol (IP) address, the time of your visit, and the referring location (e.g., the website or page that offered a link to an MSG page). Like many other websites, MSG records this basic information about visits to this Website.
Below are the cookies created by the MSG website:
- Asp.net_Sessionid: The user's session ID.
- OrginalURL: The content management system used by MSG stores these cookies when the user logs in to identify the original landing URL.
- VisitCount: The content management system used by MSG stores these cookies when the user logs in to the VisitCount for the current active server session.
Additional cookies are created by either Google AdWords or Google Analytics. Cookies with hp*, or ga* are from Google Analytics and are used to track user content viewed within our site.
MSG uses both first party cookies and third party cookies. Google Analytics and Google AdWords do not use your device's entire Internet Protocol (IP) address for analysis and its cookies do not collect personal data. You can get more information about Google's cookies, including how to manage them here: https://policies.google.com/technologies/types. MSG may also collect passive data, such as clickstream data or a user's Internet Protocol ("IP") address, operating system, browser type, time and date of visit and page views. Clickstream data is a term defined to include a record of clicked selections and other mouse activities within the Website.
In the context of an onward transfer, M-S-G has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. M-S-G shall remain liable under the Privacy Shield Principles if its agent (e.g., 3rd party) processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
You should remember that whenever you voluntarily disclose personal information online, such as on message boards, through e-mail, discussion groups, or in chat areas, your information can be collected and used by others. Although MSG tries to protect your personal information, MSG cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are solely responsible for maintaining the secrecy of any passwords you set up and/or any account information.
HOW AND WHEN INFORMATION IS USED
We use information in different ways, depending on the type of information: User-Supplied Information: This information is used for purposes such as personalization and verification. We also use this information to improve our internal operations, as well as to ensure that we: (i) bill you properly; (ii) administer your account in accordance with your agreements with us, including processing and fulfilling your purchases of products; (iii) customize the advertising and content that you see; (iv) properly perform any services you have requested; and (v) communicate with you about this Website, our products, your orders and deliveries and service announcements.
MSG may supplement the personal information you submit to us with information obtained from third parties.
UNSUBSCRIBE OR OPTING OUT
Opting Out of MSG Marketing Communications: MSG maintains contact lists to communicate with our clients and prospects. All email messages sent to these lists include an opportunity to unsubscribe or opt-out of future email messages. You may request to opt out of our marketing and information products as well as be removed from further marketing or promotional communications. To opt-out of our marketing communications, please click here.
Opting out of our Marketing Data Products and Services: To opt-out of our Marketing Data Products and Services Databases, please contact us via email at email@example.com. Your request will remove your name and address from our marketing databases.
SERVER LOG INFORMATION
This information helps us identify which areas of our Website are of interest to our visitors. MSG may also collect the Internet [Protocol] (IP) addresses of its visitors for the purposes of system administration.
Cookies and Passive Data Collection: We may use to let you use our Website more easily and to let us keep track of certain statistical information that helps us improve this Website. Cookies also allow us to save preferences for you, so that you will not have to re-enter them the next time you visit.
MSG may disclose any of the information collected from you through this Website in order to: (i) comply with applicable laws; (ii) respond to government inquiries; (iii) comply with valid legal process; and (iv) protect the rights or property of MSG, the Website or Purchasers.
MINORS: THIS WEBSITE IS NOT INTENDED FOR USE BY INDIVIDUALS UNDER 18 YEARS OF AGE. ACCORDINGLY, MSG DOES NOT KNOWINGLY COLLECT, USE, OR DISCLOSE PERSONAL INFORMATION ABOUT INDIVIDUALS UNDER 18 YEARS OF AGE.
THIRD PARTY LINKS
WHILE MSG STRIVES TO SELECT THIRD PARTY PARTNERS WHO HAVE OR SHARE THE SAME STANDARDS IN REGARDS TO PRIVACY POLICIES COMPARABLE TO ITS OWN, THE USER AGREES THAT WITH RESPECT TO THOSE THIRD PARTIES, INCLUDING WITHOUT LIMITATION THE WEBSITES MSG LINKS TO, MSG DOES NOT MAKE ANY REPRESENTATION OR WARRANTY REGARDING THE SAME, NOR WILL MSG BE RESPONSIBLE TO THE USER OR ANYONE ELSE FOR ANY PRODUCTS, SERVICES OR OTHER MATERIAL THAT MAY BE SOLD, LICENSED, DISTRIBUTED OR PROMOTED BY SUCH THIRD PARTIES OR ON SUCH WEBSITES, OR FOR ANY CONTENT ON SUCH WEBSITES. MSG ENCOURAGES VISITORS OF THESE WEBSITES TO REVIEW THE PRIVACY POLICIES POSTED ON THESE WEBSITES.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, while we strive to protect your personal information, MSG cannot guarantee or warrant the security of any information you transmit to us. You transmit all such information at your own risk. However, once we receive your transmission, we make our best effort to ensure its security on our servers.
Questions regarding the above statement should be directed to MSG for clarification.
COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES
Marketing Systems Group complies with the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union and Switzerland to the United States respectively. Marketing Systems Group has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov.
You have the right to access the Personal Information that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Information where it is inaccurate, or has been processed in violation of the EU-US Privacy Shield Principles. When updating your Personal Information, we may ask you to verify your identity before we can act upon your request.
You may also, if governed by the General Data Protection Regulations, object to the use or processing of your Personal Information or withdraw consent to use your Personal Information at any time.
Under the General Data Protection Regulations, regarding the processing of your Personal Information, you have the following rights:
- the right to require free of charge (i) information whether your Personal Information is retained and (ii) access to and/or (iii) duplicates of the Personal Information retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;
- the right to request proper rectification, removal or restriction of your Personal Information;
- where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);
- where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question; the right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you and
- the right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.
To exercise the rights referred to above, please contact us at firstname.lastname@example.org.
As far as we process your Personal Information on the basis of our legitimate interests pursuant to Art. 6 1) lit. f) GDPR, you may object to processing at any time. You may find the detailed description of our processing activities and the legal basis in the sections above. If you object, we will no longer process your Personal Information unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.
Please note that the processing of your Personal Information may involve advertising activities as described above. If you do not want that we process your Personal Information for direct marketing activities, you can object free of charge at any time via e-mail email@example.com.
Marketing Systems Group will obtain your consent before sharing your Personal Information with any third party that is not acting as an agent or vendor to perform tasks on our behalf or to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you. An exception to this will be (among others) where Marketing Systems Group’s processing of Personal Information is necessary for compliance with a legal obligation under the applicable law.
If you are a citizen of the EU, for processing of your sensitive information (e.g. medical information, Personal Information revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural's person sex life or sexual orientation) in the EU, we will obtain your explicit consent.
Marketing Systems Group is among others not required to obtain explicit consent with respect to sensitive information where the processing is (a) necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent; (b) necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity; (c) necessary to carry out Marketing Systems Group’s obligations in the field of employment law in so far as it is authorized by European Union or Member State Law or a collective agreement pursuant to Member State Law providing for appropriate safeguards for the fundamental rights and the interests of the data subject; or (e) related to information that is manifestly made public by the individual.
If you have any complaints regarding our compliance with this Policy or a Privacy Shield related or general privacy related complaint, you should first contact us via email at firstname.lastname@example.org. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Policy.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S. based third party dispute resolution provider (free of charge) at http://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint
Marketing Systems Group has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive a timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit http://insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.
With respect to human resources data, Marketing Systems Group will cooperate and comply with the EU DPA's and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with the advice given by such authorities with respect to human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgement of your complaint from Marketing Systems Group, or if we have not addressed your complaint to your satisfaction, you may contact the EU DPA's for more information or to file a complaint. The services of the EU DPA's are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you have the possibility to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Marketing Systems Group is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Effective Date: 5/23/2018
Date Last Revised: 11/30/2018