Privacy Policy

Apr 7, 2024

Last updated: April 7, 2024

Sportority Inc., and its affiliated companies (“Minute Media,” “we," “us,” or “our”) are dedicated to providing you with transparency and control over our use of your Data, ensuring that your privacy is protected and processed in compliance with applicable data protection laws. In order for us to provide you with our Services, we may collect and process certain information about you and your activities in relation to our Services (“Data”), including information that is considered “personal information” or “personal data” under applicable laws.

This Privacy Policy (“Policy”) explains how we collect, use, process, and disclose your information in connection the provision of our services and products, including, without limitation, our print and digital publications such as Sports Illustrated, 90MIN, The Players Tribune, MentalFloss, Fansided and the operation of our websites and mobile apps (hereinafter our “Websites”), where this Privacy Policy is posted or made available (collectively the “Services”).

(1) What Type of Data Do We Collect and How Do We Receive That Data?

(2) How Do We Use the Data We Collect?

(3) How and With Whom Do We Share Your Data?

(4) How Do We Use Cookies and Other Tracking Technologies?

(5) What Rights and Choices Do You Have With Respect to Your Data?

(6) How Do We Protect Your Data?

(7) How Long Do We Retain Your Data?

(8) US State Supplement (including California)

(9) International Supplement (UK, EEA, Brazil and Canada)

(10) What is Our Policy Toward Children?

(11) Updates to this Policy

(12) Controlling Version

(13) How to Contact Us

(1) What Type of Data Do We Collect and How Do We Receive That Data?

In the course of your use of the Services, we may use different technologies and ask you to provide us with certain Data to help us provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites as otherwise indicated in this Policy. We may collect the following Data about you in the following ways.

a. User-Provided Information

Some of our Services allow you to provide information to us about yourself. This may include:

When you sign up for an event or to receive our newsletter, when you communicate with us (for example, when you send us a message, submit a support ticket, or submit a form for other purposes), or otherwise communicate with us in relation to the Services, we may receive certain Data, such as: your name, email address, physical address or other information you provide or that is included in such communications.
When you create an account or register for our Services, we may also collect certain Data, such as your email address, profile photo, age and country/state of residence.
When you make purchases including subscribing to our print and digital magazines, request a refund, return or exchange or redeem a discount, your payment data such as your payment instrument number (such as a credit card number) and billing information will be collected, though this Data is usually processed on our behalf by third-party payment processors, and is not retained by us.
When you participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums, content publishing ("Activity") and when you choose to provide it, we may also collect information about your personal or professional interests, lifestyle, favorites and opinions about various topics, products, programs and services. The type of information collected may be influenced by the nature of our Website conducting the Activity (e.g. a home decor website may ask for information on the type of home you live in, and whether you are a renting or a home owner). Such information may include your full name, information regarding your marital/relationship status and number of children, gender, year of birth, your state and city of residency, employment status, your astrological sign, and any additional information you choose to provide in connection to such Activity.

b. Automatically Collected Information

When you use certain of our Services, including our Websites, our servers automatically collect certain information from your devices, including:

Device information – this includes Data such as your device ID, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, and network connection type (e.g., Wi-Fi, cellular).
Internet or other electronic network activity information - our Services may collect or use your internet protocol address, unique identifiers and other information regarding your interaction with our Services.
Geolocation Data – our Services may use information regarding your general location. We do not collect or process precise geo-location data.

We also collect information regarding your interactions with our Websites and email marketing messages, including interactions with advertisements displayed on the Websites. We and our third-party business partners may collect this information through the use of tracking tools such as cookies, pixels, JavaScript, web beacons, and SDKs. You can learn more about the tracking tools we use by visiting our Cookie Policy. Additionally, residents of some U.S. states, the UK, the EEA and other applicable jurisdictions may use our Cookie Settings tool to learn more and to change their preferences.

c. Information Received From and Through Third-Parties

We may receive your Data from third parties such as social media platforms (for example your name and username, when you register or log-in to our Services using a social media account), fraud prevention agencies and other business partners such as advertisers or app platforms that may provide us with data such as pseudonymous advertiser identifiers. We may also obtain Data from third-party business partners such as sponsors, promotional partners or other strategic partners, companies you direct to send information to us, and companies that provide us with information to enhance Data we have about you or your device to better understand our customers and to provide and enhance our Services. In some cases, we may collect Data from websites and tools offered by companies that are not affiliated with us, but that are linked to or integrated into our Services or provide links to our Services. Your interactions with websites and tools offered by companies that are not affiliated with us are covered by the privacy policies of those companies, not this Privacy Policy.

If you choose to use third party devices and technologies (such as Amazon Alexa or Google Assistant) in connection with our Services, the operators of those third-party devices and technologies will process your information in connection with their own terms of service and privacy policies, which you should review. Those operators may provide us with certain information related to your use of those devices, including the audio you provide (to learn more about Amazon Alexa and Google Assistant data processing, please visit Google's policies, here and here; and Amazon's policies: here and here).

(2) How Do We Use the Data We Collect?

Provision of Services - for the provision and improvement of our Services to you, including for support, responding to your queries, providing you with a customized experience (for example, by remembering choices you make when you use the Services) and processing of payments as stated in Section 1 above.
Communications - we may send you communications, including by email, push notifications, or text, about purchases, your account, offers, changes to policies, customer service inquiries, to request feedback or to keep you informed of our latest updates to our Services.
Marketing and advertising purposes - by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also use your Data in the following ways: we may send you promotional material concerning our Services, or our partners' services, which we believe might interest you; we may also display certain ads on our Services, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building a profile based on your Data.
Collaborating with third parties – we may partner with third party businesses to receive or share your Data for Data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to opt-out options set forth in this Policy.
Improve our Services - we may conduct surveys or test features, and analyze the Data we have to develop, maintain, measure and improve our Services and think of new and exciting features for our users.
Operate our business: we may use Data to support our internal business functions, including finance, accounting and audit.
With your consent – we may use your Data with your consent for other purposes described at the point of collection.

Protecting our interests - we may use your Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of Minute Media, its users and/or partners.
Enforcing of policies - we may use your Data in order to enforce our policies and relevant terms of use of our Brand Websites.
Maintenance of security and compliance with legal and regulatory requirements - we may use your Data to detect and prevent fraud by verifying your identity, maintain the integrity and security of the Services, investigate violations, and as otherwise required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

(3) How and With Whom Do We Share Your Data?

We may disclose the information we collect from and about you as described below.

1. Affiliates

We share your information with companies in our group in connection with any of the uses of your Data set out in this Privacy Policy.

2. Service Providers

Vendors and service providers – we hire vendors and other companies to perform services for us such as creation, maintenance, hosting, delivery and marketing of our Services and provision of third-party advertising. These service providers may have access to your Data so that they may perform these tasks on our behalf, but they are obligated to comply with contractual privacy obligations.

3. Business partners

We may disclose your Data to third-party businesses for their own purposes, including marketing products or services to you, showing you relevant advertising, or providing an enhanced experience that integrates with our Services. For example, we may offer content or Activities (e.g., competitions, sweepstakes, promotions, games,) that are sponsored by or co-branded with third parties which may collect or obtain Data from participants. We may also share your Data for Data segmentation, enrichment and optimization purposes, which allow us or our partners to personalize and optimize the Services, advertisements and marketing activities we or they offer you. In some jurisdictions, this is subject to consent or opt-out options set forth in this Policy.

We share Data collected in connection with the Sports Illustrated business with ABG-SI LLC, the owner and licensor of the Sports Illustrated trademarks. ABG-SI acts as a separate “business” / data controller and uses the Sports Illustrated Data in the manner set forth in its Privacy Policy at: https://corporate.authentic.com/privacy-policy

4. User Profiles and Submissions

Certain user profile information, including your name, location, and any related video or image content you uploaded to the Services for publication, may be displayed to other users as part of the Services, to facilitate user interaction within the Services or address your request for our Services. Please remember that any content you upload to your public user profile, along with any Data or content that you voluntarily disclose online in a manner other users can view (e.g., on your published content, forums, discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your name/username may also be displayed to other users if and when you send messages or comments or upload images, content or videos through the Services.

5. Compliance with Laws and Law Enforcement Entities

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any Data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

6. Mergers and acquisitions

We may share your Data if we enter into a business transaction such as a merger, divestiture, acquisition, restructuring, reorganization, dissolution, bankruptcy, or other sale or transfer or business transaction involving all or part of our company or assets, including for the purposes of determining whether to proceed with such transaction. Any party that acquires our assets as part of such a transaction may continue to use your Data in accordance with the terms of this Policy.

7. Activities

When you register for or enter an Activity through our Services, we may disclose the information you provide for such purposes to certain third-party service providers, participating sponsors, and advertising partners. By entering into any Activity, you agree to the official rules governing that Activity, which may include a requirement that you allow us or the sponsor of that Activity to use and publicly release your name, voice and/or likeness in advertising for or associated with the Activity.

8. Others

We may otherwise disclose information if you ask or authorize us to do so, including by interacting with third parties on our Websites. We are not responsible for events arising from distribution of your information that you choose to disclose publicly through our services.

9. Aggregate information

We may opt to aggregate and/or de-identify information such that it is no longer able to be linked to you or your device(s). This Policy does not limit our ability to use or disclose such aggregated or de-identified information, which we may disclose in our sole discretion.

(4) How Do We Use Cookies and Other Tracking Technologies?

A cookie or other tracking technology is a small piece of script or code that is stored on your browser or device to help websites and apps remember you and collect information about your use of the Services. When you visit or access our Services we use (and authorize third parties to use) pixels, cookies, web beacons, SDKs and other tracking technologies. These technologies help recognize your browser or device and automatically collect information about you, your device and your online behavior to provide certain features on our Services, enhance your navigation in our Services, improve our Websites’ performance, maintain your preferences, perform analytics and customize your experience. In addition, we and third-party advertising companies may use this information to help serve advertising tailored to your interests, both on and off our Services. These technologies also help measure interaction with advertisements across our Services, marketing emails and third-party websites, apps, devices and services.

To learn more about how we and our partners use tracking technologies please visit our Cookie Policy. Additionally, please see the US State Supplement and International Supplement for more information about choices individuals residing in certain US states, the UK, the EEA and other relevant jurisdictions have with respect to information collected via these tracking technologies.

(5) What Rights and Choices Do You Have With Respect to Your Data?

a. Email Communication Preferences.

You may opt out of receiving promotional emails from us by clicking on the “Unsubscribe” link at the bottom of the email. You also may tell us that you do not want to receive our promotional messages by emailing us at contactus@minutemedia.com (kindly specify the name of the relevant product from which you wish to unsubscribe from). Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. If you subscribed to any of our partners' service, please note we will have no control over our partners' communications, and in order to unsubscribe from it please contact the relevant partner or use the "unsubscribe" link in its emails.

b. Push Notifications.

If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our relevant app.

c. Browser and Device Settings. You may have more options depending on your mobile device, operating system, or browser. Please review the support materials and/or the privacy settings for the respective devices and systems to learn more about these features and how they apply to targeted advertisements. Blocking cookies may also prevent you from accessing some of our content or Service features.

d. Targeted Advertising.

You can opt out of targeted advertising on websites and apps by third parties that participate in self-regulatory programs via the following links:

Websites: The Digital Advertising Alliance (DAA) WebChoices and Network Advertising Initiative (NAI) WebChoices
Mobile: DAA AppChoices and NAI Mobile Choices

In some jurisdictions, including some US states, the UK, the EEA and other applicable jurisdictions, you can also opt out of targeted advertising through consent tools available on our Websites, as more fully described in our Cookie Policy and in the US State Supplement and International Supplement below.

e. Data “Sales.”

In some jurisdictions, you may have the right to opt-out from the “sale” (as defined under applicable privacy laws) of your Data to third parties by using our designated tools (such as opt-out banners, cookie preference banners, Do-Not-Sell buttons, etc.), as well as by contacting us in the manner set forth below. Please see our US State Supplement and International Supplement for more information.

f. Individual Rights.

In addition to the rights noted above, depending on your country (or in the United States, your US state) of residence, you may be afforded, in accordance with applicable law, certain other rights with respect to your Data, such as the right to:

obtain information about the personal information we have collected about you and to request a copy of it;
delete certain personal information we have about you;
request correction of inaccurate personal information we have about you;
object to or request the restriction of processing of your personal information;
request that your data be transferred to another organization; or
withdraw your consent with respect to any processing of Data which is based on your consent.

For more information about what rights may be available to you depending on your country or state of residence, please see the US State Supplement (if you reside in the United States) or the International Supplement (if you reside outside the United States).

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. We reserve the right to deny requests as allowed by applicable law, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, or where we must retain your Information consistent with applicable law. Our goal is to respond to a verifiable consumer request within 45 days (for US residents), or 30 days (for UK and EEA residents) of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the initial response period. We will deliver our written response, electronically. If reasonably possible, we will provide your Data in a format that is readily useable and should allow you to transmit the information without hindrance.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available to you may change or no longer be available to you.

(6) How Do We Protect Your Data?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Data. Your Data is stored on secure servers and isn’t publicly available. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Data, we cannot ensure or warrant the security and privacy of your Data or other content you transmit using the Services, and you do so at your own risk.

(7) How Long Do We Retain Your Data?

We will retain your Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal Data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

(8) US State Supplement (including California)

Some US state laws require us to inform residents of those states about additional privacy information and rights. Please visit our US State Supplement for additional information.

(9) International Supplement (UK, EEA, Brazil and Canada)

The laws in some countries, including the United Kingdom, countries in the EEA, Brazil and Canada require us to inform residents of those countries about additional privacy information and rights. Please visit our International Supplement for additional information.

(10) What is our Policy Toward Children?

We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and you believe we have collected your child’s information, please contact us at contactus@minutemedia.com.

(11) Updates to this Policy

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. Any changes will be effective upon posting of the revised Policy. By continuing to use the Services after that date, you consent to any and all changes, unless applicable law requires us to provide another form of notice and/or obtain your consent to such changes.

(12) Controlling Version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

(13) How to Contact Us?

Please contact us regarding any questions or complaints pertaining to this Privacy Policy or our privacy practices at dpo@minutemedia.com. Please be advised that dpo@minutemedia.com is designated solely for privacy related inquiries of our users, and we reserve the right to not respond to any non-privacy inquiries that are sent via the privacy email address. For any non-privacy inquiries, please see send an email to helpdesk@minutemedia.com.

Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.

US State Supplement

Last Updated: April 7, 2024

This US State Supplement provides information for residents of California, Connecticut, Colorado, Nevada, Utah and Virginia. In addition, this Supplement will apply to residents of Texas and Oregon as of July 1, 2024 and to residents of Montana as of October 1, 2024. These state laws provide residents certain rights, which you can exercise as set forth below.

Our general Privacy Policy explains what Data we collect about you, how we collect that Data and why and how we use and disclose that information. Individuals who reside in California, Connecticut, Colorado, Nevada, Utah and Virginia should read this Supplement as well as our Privacy Policy to fully understand our collection, use, and disclosure of your Data.

Any capitalized terms we do not define in this Supplement are defined in our Privacy Policy.

(1) Your Rights

Your rights as specified under state law may include the following:

Delete your personal information/data. Upon your request, we will delete the personal information we have collected about you, subject to certain legally-permissible exceptions.
Access your personal information/data or receive information regarding our processing of your personal information/data. You have the right to access a copy of personal information/data that we have collected about you or to ask us to confirm whether we process your personal information/data.
Correct inaccurate personal information/data. You have the right to request that we correct any inaccuracies in the personal information/data we have collected about you.
Opt-out of the “sale” of your personal information/data. You have the right to tell us not to “sell” your personal information/data according to applicable law.
Restrict our use of your personal information/data for targeted advertising. You may ask us not to use or disclose your personal information for targeted advertising. Please note that, even if you exercise your right to restrict your use of personal information for targeted advertising, we will continue to collect and use your personal information/data for other purposes.

We do not use or disclose personal information for profiling in furtherance of decisions that produce legal or similarly significant effects on you without either your explicit consent or where otherwise permitted by applicable law. If you are a California resident, additional information about your rights is provided in Section (3) below.

(2) How to Exercise Your Rights

To exercise your rights to delete, access or correct your personal information/data, please send us an email at contactus@minutemedia.com. To prevent fraud and verify your identity, we usually ask you provide an email address when you submit a request. You may also designate an authorized agent to submit a request on your behalf. Depending on the nature of your request, we may ask that you verify that the request comes from you such as by requiring a signed written permission from you that authorizes the agent to act on your behalf. A valid power of attorney will constitute signed written permission, but you are not required to obtain a power of attorney to use an authorized agent.

If we deny your request or cannot fulfill it, you may appeal our decision by contacting us via contactus@minutemedia.com to ask us to review your request again. Your email should include “Appeal” in the subject line. You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this US State Supplement.

Requests to Opt Out of “Sale” of Personal Information/Data or to Limit Use of Personal Information/Data for Targeted Advertising

If you do not want us to “sell” your personal information/data to third parties or if you wish to limit use of your personal information/data for targeted advertising, please use the consent management tool available on the homepages of our Websites.

After you opt-out of “sales,” we may continue to share some personal information/data with our partners (who will function as our service providers or processors in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the personal information/data collected when you use those devices or browsers.

(3) California

California residents should review the below California-specific disclosures and metrics provided in accordance with California law.

For purposes of this section, the “CCPA” shall mean Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act of 2020, and the regulations promogulated thereunder.

In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of personal information:

Personal and online identifiers, such as full name, email address, postal address, social media identifiers, photos, IP address, UDID, advertising IDs.
Commercial and transactional information, such as full name, billing information, credit card number.
Internet or other electronic network activity information, such as searches on our Services and information about your interactions with our Services and any advertisements thereon.
Geolocation information.

We collect personal information from you and from the following categories of services:

Our affiliates and Partners;
Payment processors;
Advertising networks;
Data analytics providers;
ID companies;
Data segmentation providers; and
Cloud services.

Consumer Requests Metrics

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to April 20th of the following year)

	Completed	Mean Number of Days to Substantive Response
Requests to Delete	35	Up to 72 hours from the day of applicable request
Requests to Know	0	Up to 72 hours from the day of applicable request
Requests to Opt Out of Sale	206,768	Immediate

Children under 16. We do not “share” or “sell” (as defined under California law) personal information of children we know are under 16 years of age.

Sensitive Personal Information. We do not use or disclose “sensitive personal information” (as defined under California law) in any way that would require us to provide an opt-out opportunity under California law.

International Supplement (UK, EEA, Brazil and Canada)

Last Updated: April 7, 2024

This International Supplement provides information for residents of certain countries outside the United States which have data protection laws with specific requirements that are addressed in this Supplement, including the UK, the EEA, Brazil and Canada.

Our general Privacy Policy explains what information we collect about you, how we collect that information and why and how we use and disclose that information. Individuals who reside in the UK, EEA, Brazil and Canada should read this International Supplement as well as our Privacy Policy to fully understand our collection, use, and disclosure of your information.

Any capitalized terms we do not define in this International Supplement are defined in our Privacy Policy.

(1) UK and EEA

With respect to processing of personal Data on residents of the EU, we participate in the IAB Europe Transparency & Consent Framework, and comply with the Policies and Specifications and with the Transparency & Consent Framework provided by IAB Europe. Our IAB Europe vendor ID is 918.

For the purposes of this Supplement, “Process”, “Processed” and “Processing” includes the collection, storage, use, disclosure and processing, as applicable, of your Personal Data.

a. Why do we Process your Data?

Your Data will be processed with your consent and/or for the purposes and the corresponding legal bases as described in more detail below, as applicable.

Purpose	Legal basis (if and when required under applicable laws)
Provision of our Services; support; service announcements; push notifications; analytics, surveys and research; protecting our interests; enforcing of policies; We and our Partners may use your Personal Data, such as your name and email address, for operational purposes, for example, responding to your inquiries. In other instances we may, for example, use your Personal Data to send you notifications and communications if you opted in and/or accepted to receive them from us, or if they are relevant to your use of our Services (such as service announcements).	The legal bases for Processing this Data are the performance of our contractual obligations towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.
Payments. We collect from our third-party payment processors certain information about your payment instruments for the purpose of completing any transaction requested by you, and sending to you statements, invoices, or receipts.	The legal bases for Processing this Data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.
Improve our Services. We and our Partners may collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services.	The legal bases for Processing this Data are our legitimate interests, in this case – providing and improving our Services. Where analytics Data containing personal Data is collected through cookies and similar Tracking Technologies (as further described below) we rely on your consent, where required.
Marketing and Advertising; We may use Tracking Technologies (which may collect Personal Data) in order to provide you with personalized advertisements when you visit our Services.	The legal bases for processing this Data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests.
Third Party Advertising and Data Segmentation; We may share your personal Data with third party ad networks and Data segmentation solution companies to enrich, segment or optimize your Data for marketing and advertising purposes of ourselves and our business partners.	The legal bases for Processing this Data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests, and assisting our business partners to do the same. As explained below, where applicable, you will have the option to opt-out from such Processing.
Integrity. We may Process certain information about you and your usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.	The legal bases for Processing this Data are your consent (where required), compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services and the safety of our end-users.
Compliance with applicable laws, legal and regulatory requirements.	We may be required to collect, retain, or share your Data, under applicable laws.

b. Transfer of Data Outside the EEA, UK

We operate globally, thus any information that we collect, disclose or share, including your personal data, can be stored and processed in various other jurisdictions around the world (“Other Jurisdictions”), including (but not limited to) the United States and Canada, for the purposes detailed in this Policy. We will transfer your personal data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to Data recipients:

located in the EEA or in the UK;
located in non-EEA countries or non-UK which have been approved as providing adequate level of Data protection; or
who have entered into legal agreements and performed assessments ensuring an adequate level of Data protection by the recipient.

You can obtain more information about our policies and practices with respect to the use of service providers located in Other Jurisdictions by contacting us as described in our Privacy Policy under the “How to Contact Us” heading.

c. Data Subject Rights

If you reside within the European Union or the UK, you may request to:

Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
Request rectification of your Personal Data that is in our control.
Object to the processing of Personal Data by us.
Request to restrict processing of your Personal Data by us.
Request erasure of your Personal Data.
Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU and UK residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. If you, as EU of UK resident, would like to exercise any of the rights mentioned in this section, please see below.

d. Additional Information

If you reside in the EEA or UK, we will be the controller of your Personal Data provided to, collected by or for, or processed by us in connection with our Services. In addition to the abovementioned, Partners also act as Data controllers for the personal Data that we share with them and any personal Data that Partners may collect independent of our relationship with them. If you have any questions about the processing of your personal Data by a Partner, you should contact the Partner directly.

All requests, complaints and queries should be addressed to us by submitting a verifiable consumer request to our email address: dpo@minutemedia.com (please provide the required details as set out below).

We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable Data protection supervisory authority.

Our representative in the European Union is Lionheart Squared (Europe) Ltd., 2 Pembroke House, Upper Pembroke Street 28-32, Dublin, D02 EK84 Ireland, and their email address is: MinuteMedia@lionheartsquared.eu.

Our representative in the United Kingdom is 385-389 Oxford St. London W1C 2NB and their email address is: dpo@minutemedia.com.

In addition, you can exercise your rights via dpo@minutemedia.com, where you can submit a verifiable user request.

Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data (“Request”).

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

The Request must:

Provide sufficient information allowing us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.
Describe your Request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your Request or provide you with Personal Data if we cannot verify your identity or authority to make the Request and confirm the Personal Data relates to you. Making a verifiable Request does not require you to create an account with us. We will only use Personal Data provided in a verifiable Request to verify the requestor's identity or authority to make the Request. If you have any general questions about the Personal Data that we collect about you or how we use it, please contact us at dpo@minutemedia.com.

(2) Brazil

The following part of this International Supplement complements the general part of the Privacy Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").

Processing of Personal Data

The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.

If you reside in Brazil, you have the following rights under LGPD:

Receive confirmation as to whether or not Personal Data concerning you is being processed;
Access your Personal Data;
Correct incomplete, inaccurate or outdated Personal Data;
Request anonymization, blocking or deletion of unnecessary, excessive Personal Data;
Request Data portability to another service provider or product, upon express request, as may be provided by the appropriate law;
Request deletion of Personal Data processed with your consent;
Obtain information about the public or private entities with which we share your Personal Data;
Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given;
Revoke your consent.

If you would like to exercise any of any of the rights mentioned in this section, please contact the email address mentioned below: dpo@minutemedia.com (please provide the required details as set out in the UK/EEA section above).

(3) Canada

If you are resident in Canada, you may have certain rights (including those described below) with respect to your Personal Data that we Process. To exercise any of your privacy rights, please contact us as at dpo@minutemedia.com.

Updating your Personal Data – We want to make sure that the Personal Data that we have collected about you is accurate, complete, and current. However, we may not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Data. Since we generally rely on you to inform us if there have been any changes to the Personal Data that we have collected about you, please let us know if any of this information has changed.
Access to and Correction of Personal Data – If you have any questions about the accuracy of the Personal Data that we have collected about you, you can have access to that Personal Data in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Data.
Withdrawal of Consent – Where you have provided your consent to the Processing of your Personal Data, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
Unsubscribe from Marketing and Promotional Communications – If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g., email) you receive or by contacting us as set out below under the “How to Contact Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transaction emails or emails about your account and use of our Websites.

(4) Job Candidates from the EU and Canada

Personal Data of job candidates who apply for any of our and our affiliated companies’ open jobs in the EU or Canada (“Candidates”), is also subject to this Policy, and in addition, to the terms specifically provided in this section, which shall prevail over the rest of the terms of this Policy in case of inconsistency. Within an application of a Candidate, we may collect certain Personal Data about the Candidate, as provided by the Candidate, such as: resume, contact details, occupation data and other related information (“Candidate Data”).

Our main management and retention platform provider for Candidate Data is Comeet Technologies Inc. (“Comeet”). Candidates are welcome to review Comeet’s Privacy Policy at: https://help.comeet.com/en/articles/3134994-privacy-notice.

Candidates should not apply for a job and provide us with their Data, unless they have read and agreed to this Policy and Comeet’s Privacy Policy.

A Candidate may also apply for a position via third parties (such as: LinkedIn, Glassdoor, placement companies, etc.), who may provide us with Candidate’s Personal Data on Candidate’s behalf. Any Personal Data that we receive via from such third parties may be subject to this Policy, but each Candidate is requested to review the privacy policies of such third parties (of which we do not assume any liability for) prior to providing us with any Personal Data via their services.
We aim to protect the privacy of Candidate Data and use such Data solely for our and our affiliated companies’ internal recruitment purposes (inter alia, for contacting the Candidates, evaluating them for a specific position, etc.). In case a Candidate provides a reference, certain necessary relevant Candidate Data may be inevitably revealed to such reference in the process of a reference check (e.g., the fact that Candidate is searching for a new job, and any other relevant information included in Candidate’s resume, etc.), and thus a Candidate should not provide a reference in case Candidate does not wish such information to be disclosed.
We retain Candidate Data within Comeet for no longer than thirty-six (36) months after the last activity was made in relation to a Candidate on Comeet, unless the Candidate has provided consent for a longer period of retention. Resumes, and Candidate Data provided to us via other means, may be retained in other systems for longer periods, subject to the general retention framework specified in this Policy under the “Retention” section below. The purpose of retaining Candidate Data is to enable us to contact a Candidate who we find suitable in order to inform the Candidate of a new job vacancy, and in order to use such Data in case the Candidate contacts us again and applies for the same or a different position.
If you wish to exercise any of your “European Users' Rights” specified above or receive more information regarding Candidate Data, please contact our Data Protection Officer (“DPO”) using the details provided below. Kindly specify that your request is related to your Candidate Data. Email: dpo@minutemedia.com.

Published Apr 4, 2024|Modified Apr 7, 2024