Privacy Policy

Effective Date: July 1, 2017

To review material modifications and their effective dates scroll to the bottom of the page.

In The Mitten Media, Inc. (“ITMM”) owns and operates this inthemittenmedia.com website business. All references to “we”, “us”, this “website” or this “site” shall be construed to mean ITMM.

If you are a resident of the European Economic Area (EEA) consisting of the EU, plus Norway, Iceland, and Liechtenstein, you have specific rights as described in this Privacy Policy. We may act as the controller if we collect Personal Data from you directly. We may also act as the processor if we process data transmitted from our subscribers that have contracted for access and use of our online services.

HOW WE MODIFY THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy that is always accessible by clicking on the “Privacy Policy” link on this site’s home page. Your continued use of this site indicates your acceptance of the amended Privacy Policy.

Regarding Personal Information (defined below), if any modifications are materially less restrictive on our use or disclosure of the Personal Information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using Personal Data described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it’s not overridden by your rights
• For payment processing purposes
• To comply with the law

THE TYPES OF DATA WE COLLECT

Personal Data.

“Personal Data” means data about a living individual who can be identified from those data (or from those data and other information either in our possession or likely to come into our possession).

Personal Data may include, but is not limited to:

• First name and last name
• Email address
• Phone number
• Business name
• Website URL
• Address, State, Province, ZIP/Postal code, City
• Any Personal Data you post on our website
• Any Personal Data you post on a social media platform
• Data about how you use our website
• Technical data such as your IP address, your login data, details about your browser, time zone settings and other technology on the device you use to access our website
• Your marketing and communication preferences
• Any information that you directly provide to us whether through our contact form ,over the phone, by email or otherwise
• Geo-location data
• Cookies and Usage Data

Passively or Automatically Collected Data (“Usage Data”).

We may also collect information regarding how our service is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Geo-Location Data. If you are accessing a page from a computer or a mobile device, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience when we work with a marketing partner such as a third-party service provider, advertiser, or advertising network and platform. If you agree to the collection of location data, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device.

HOW AND WHEN WE COLLECT DATA

Personal Information. We collect Personal Information at the time you provide it to us. We collect Personal Information through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest from this website. Personal Information that we collect may vary with the each sign-up or registration. In addition, we collect personal information from all communications with site visitors including without limitation, text messages, faxes, telephone calls, and regular “snail mail”, as well as from third-party outside sources including database vendors.

Your Communications With Us. We collect Personal Information that we receive from you as you communicate with us. If you complete a signup form subscribing to information from our site or to participate in our mailing list activities, we will receive your Personal Information from our email services and/or autoresponder service.

Usage Data. We reserve the right to monitor your use of this site. As you navigate through this site, Usage Data may be passively collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies and web beacons.

HOW WE USE YOUR DATA

We may use your Personal Information only for the performance of the services or transaction for which it was given, and our private, internal reporting for this site, and security assessments for this site.

We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends about the use of this site, and otherwise administer and improve this site for your use. Specific uses are described below.

RETENTION OF DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

TRANSFER OF DATA

We are located in the United States. Your submission of your Personal Data via this website will transfer your Personal Data to us.  We will not transfer your Personal Data outside the United States unless the transfer is made to a country or territory recognized by the EU as having an adequate level of data security, or is made with your consent, or is made to satisfy our legitimate interest regarding our contractual arrangements with our subscribers that have contracted for access and use of our online services.

Your consent to this Privacy Policy followed by your submission of your data to us signifies your agreement with these transfers and storage of your data.

DISCLOSURE OF DATA

General Disclosure Policy. We reserve the right to disclose your Personal Information as described below. We reserve the right to disclose Usage Data without restriction.

Affiliated Entities. We reserve the right to provide your Personal Information and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.

Service Providers. We reserve the right to provide access to your Personal Information and Usage Data to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting services. Our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your Personal Information and Usage Data. In such an event, we will require the buyer or transferee to agree to our commitments provided in this Privacy Policy.

Legal Process, Enforcement and Security Notice. We reserve the right to disclose your Personal Information and Usage Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site.

When We Participate In a Joint Venture With Marketing Partners. We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions, or contests. We reserve the right to disclose your Personal Information to them for purposes of (i) compensation, transaction processing, fulfillment, and support, and (ii) for purposes of offering you other products, services, promotions, and contests. These joint venture marketing partners may also contact you regarding other products, services, promotions, or contests.

Your California Privacy Rights. Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the

European Economic Area (EEA).

SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS

In order to provide better service for our site, we may use Cookies and Web Beacons to collect Usage Data to store your preferences and information about what pages you visit and past activity at our site. We may also employ Web Beacons from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our site.

“Cookies” are tiny pieces of information stored by your browser on your computer’s hard drive. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our site.

Flash Cookies – third party cookies that use an Adobe Flash Media Player local shared object (LSO) – may be used along with other third party cookies for purposes of crediting any purchase you may make on this site to one of our joint venture marketing partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as “browser cookies”. The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.

Web Beacons – sometimes called single-pixel gifs or clear gifs – are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or other communications in order to determine whether messages have been opened and acted upon.

ANALYTICS

We reserve the right to participate with third party analytics partners to monitor and analyze Web traffic and can be used to keep track of user behavior on this site.

Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. Information collected: cookie and Usage Data. Visit Privacy Policy at https://www.google.com/intl/en/policies/?fg=1 You may optout of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout/Clicky Web Analytics (Clicky) – Clicky Web Analytics is a web analysis service provided by Roxr Software, Ltd. (“Clicky”). Clicky utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Clicky services. Information collected: cookie and Usage Data. Visit Privacy Policy at http://clicky.com/terms

SOCIAL MEDIA INTERACTIONS

We invite you to socialize and share your participation with this site and purchases. If you choose to use social media platforms such as Facebook, Twitter, Pinterest, and Instagram, you will be allowing interaction with these platforms or other external platforms directly from this site, and in the process you may be sharing certain profile elements, including your comments. This sharing is subject to each social media program’s privacy policies.

DO NOT TRACK REQUESTS

Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.

DATA SECURITY

We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site.

When you transmit Personal Information through our registration process or if you purchase products or services, we encrypt that information in transit using secure socket layer technology (SSL).

After the secure transfer of your Personal Information, the information is maintained and stored with 128-bit encryption.

ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE

Any Personal Information which we may collect on this site will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of Personal Information outside your country of residence to the United States.

UPDATING PERSONAL INFORMATION

Upon request, we will permit you to request or make changes or updates to your Personal Information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Information in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.

LINKS TO JOINT VENTURE MARKETING PARTNER SITES

This site may contain links to other websites operated by our joint venture marketing partners. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them.

CHILDREN’S ONLINE POLICY

We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 18. If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact the owner and operator of this website business at:

In The Mitten Media, Inc.

Attn: Privacy Policy Officer

75 North Main Street, Suite 214

Mt. Clemens, MI 48043 USA

Email: info@inthemittenmedia.com

Telephone: 586.330.1366

>>Material Modifications<< Since July 1, 2017: GDPR compliance.