PRIVACY, SECURITY AND TRANSPARENCY
Summary of how we handle Personal Information
We collect and retain certain personal information from different groups of data subjects encompassing: our vendors, customers and those who visit and use our online and mobile resources. Our privacy statement applies mostly to that last group, from which we collect very little information unless it is voluntarily submitted to us. You can read here to learn about the categories of personal information we collect from all four groups of data subjects.
We use personal information received from visitors and users of our online and mobile resources to communicate directly with them. Personal information collected from our workforce is used to fulfill our human resources commitments and in furtherance of our legal obligations as an employer, while personal information collected from our customers is used as needed to carry out the contracts we have with them. We provide further detail about our use of personal information here.
We share personal information when needed to fulfill our legal obligations and when our vendors need it to perform under the contracts we have with them. We provide further detail about our sharing of personal information here. We do not sell or rent any personal information from any group of data subjects to third party data brokers or marketing companies.
We’ve invested in a Security Program that addresses both technical and operational matters. Our program includes an incident response and management and vendor oversight components. You can read about those components here and here.
You do not have to provide personal information to enjoy most of the features of our online and mobile resources. Moreover, you can opt out of certain activities like announcements. You can learn more about that here.
Contacting Our Privacy Office
If you have any questions about our privacy and data security policies, procedures and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office using the information below.
Nano Media Inc.
P.O. Box 3540
Silver Springs, NV 89429
This privacy statement was amended as of June 1, 2020 and is effective as of that date. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.
NAVIGATING THROUGH THIS STATEMENT
You can use the links below to navigate to areas of this statement that apply specifically to you, or which may otherwise be of interest:
Some Important Vocabulary
What Personal Information Do We Collect?
How Do We Use the Personal Information We Collect?
When/With Whom Do We Share Personal Information?
How Do We Protect Collected Personal Information?
Your Rights And Options
Changes To This Privacy Statement
Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. Clarity is, therefore, important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement” and “our statement”, we mean the Privacy and Data Security Statement you are reading now. Wherever we say “Nano Media”, “we”, “us”, or “our”, we mean Nano Media Inc. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this statement here.
When we talk about our “online and mobile resources”, we mean all websites, portals or other features we operate to allow you to interact with us and our systems, as well as the mobile apps we’ve created and distributed to let you interact with the content we provide. An “affinity action” is when you “follow” us, “like” us or take a similar or analogous action on our external social media presence. Finally, and perhaps most importantly, when we refer to “personal information”, we mean information that can be used to identify or easily be linked to you.
The categories of information we collect from each of these groups differs. As you may have noticed, it’s possible that the same person could fall into more than one group. For instance, someone who is a customer might also work for one of our vendors. We explain below the different categories of personal information we collect from each group of data subject.
If you visit and/or use our online and mobile resources, we collect and retain a very limited amount of personal information through automated/technical means. We describe that automatic collection here. In addition to that, if you choose to participate in, or make use of certain activities and features available via our online and mobile resources, you will need to provide us with information about yourself. We describe that type of voluntary submission immediately below. By using our online and mobile resources, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.
Voluntarily Submitted Information.
Here are some of the ways you voluntarily give us your personal information. The types of personal information you will be submitting to us in these situations is almost always limited to identifiers such as your name, email address, mailing address and phone number. You can read about how we use that personal information here.
If you prefer we not receive the above-described personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on, or use the applicable features available from our online and mobile resources. Such participation and use is strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources, but most of the content in our online and mobile resources will still be available to you.
Automatically Collected Information.
When you visit or use our online and mobile resources, basic information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as “cookies.” Cookies are small text files downloaded onto your computer or mobile device. Cookies allow us to collect your IP address and recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions, such as:
Additional information about cookies and tracking technologies is available here.
If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that pinpoint the physical location of devices and we may receive this geolocation data as well.
Finally, when you use our online and mobile resources, we may allow third party service providers to place their own cookies or similar technologies in order to engage in the same types of collection we describe above. For example, we use third party “web analytics” services such as those offered by Google Analytics and Facebook Pixel. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
We maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn and our online and mobile resources may contain links to other websites or apps controlled by third parties.
HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?
We use personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis/legitimate business purpose to use your personal information before doing so. As stated in applicable law, such lawful bases/legitimate business purposes include receiving express consent, operating our business, performing a contract, and complying with a legal obligation. More specifically, we use the personal information as follows:
We use the automatically collected personal information described here to compile generic reports about popular pages/features of our online and mobile resources, and to see how users are accessing our online and mobile resources and in some cases (such as affinity actions) send materials to you. We use the personal information you voluntarily submitted, as described here, to respond back directly to you and/or send you the information you requested or about which you inquired. We also may use any such personal information you provide to customize our programs to make them more relevant to you. We do not sell or rent personal information automatically collected by, or which you voluntarily provide when using our online and mobile resources.
In addition to the uses described above for visitors and users of our online and mobile resources, if you visit our online and mobile resources and order products or services from us, you will provide us with certain information related to your order as described here. We will use your information to process your order, send you communications regarding your order and also information about other products or sales that may be of interest to you.
We use the personal information collected from our vendors (which is largely minimum business contact information) to manage, administer and perform under our contracts with them, or share information about our products. We also may from time-to-time use personal information about their individual personnel to perform background checks on those who are provided access to our facilities or technology networks so that we can help protect the personal information of others stored thereon. We describe our use of vendor personal information in greater detail in our confidential contracts with those parties.
We may share your personal information as described below. This sharing applies to the personal information of the groups of data subjects described here.
We may disclose personal information to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including responding to court orders and subpoenas.
To Prevent Harm
We also may disclose such information when we have reason to believe that someone is causing injury to or interference with our rights or property, or harming or potentially harming other persons or property.
If we sell or transfer all or substantially all of our assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.
We also share personal information with those of our vendors who need it to perform under the contracts we have with them. As part of our Security Program, we have adopted standards for those vendors who receive personal information from us. We attempt to bind such vendors to those standards via written contracts. Such standards include expectations that when we share personal information with our vendors and business partners, they will comply with all applicable privacy and data security laws and regulations and our Security Program, and will contractually require and cause their subcontractors and agents to do the same. Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to the above-described contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.
We have adopted, implemented and maintain an enterprise-wide corporate information security and privacy program that includes technical, organizational, administrative, and other security measures designed to protect, as required by applicable law (including all those described above), against reasonably anticipated or actual threats to the security of your personal information (the “Security Program”). Our Security Program was created by reference to widely recognized industry standards such as those published by the International Standards Organization, National Institute of Standards and Technology and the Payment Card Industry Security Standards Council. It includes, among many other things, procedures for assessing the need for, and as appropriate, either employing encryption and multi-factor authentication or using equivalent compensating controls. We therefore have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Despite the significant investment we’ve made in, and our commitment to, the Security Program including enforcement of our third party oversight procedures, we cannot guarantee that your personal information, whether during transmission or while stored on our systems, otherwise in our care, or the care of our vendors and business partners, will be free from either failed or successful attempts at unauthorized access or that loss or destruction will never occur. Except for our duty to maintain the Security Program under applicable law, we therefore necessarily disclaim, to the maximum extent the law allows, any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.
If we are using your personal information to send you marketing materials, such as product alerts via text or email, you may opt out by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend and delete your personal information by contacting us using the contact information below. Opting out of or changing affinity actions or other submissions or requests made on our third party social media platform, will likely require that you do so directly on that platform as we do not control their procedures.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not specifically respond to browser “do not track” signals.
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.
We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this statement. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new statement.
If you have questions about our privacy statement or privacy practices, please contact Our Privacy Office:
Nano Media Inc.
P.O. Box 3540
Silver Springs, NV 89429