Privacy Policy
Effective Date: May 21, 2024
Effective Date: May 21, 2024
This Privacy Policy (“Privacy Policy”) describes how your personal information is collected, used, and shared by Memoramedia Inc. (“Cllct,” “we,” “us,” and “our”) when you visit websites or services controlled by Cllct where this Privacy Policy is posted (collectively, the “Sites”). We may update this Privacy Policy from time to time, as detailed below. You should not use the Sites if you have any objections to our Privacy Policy, which is binding upon all users of the Sites. If you have a question about how your personal information is being used, you can contact us through the methods provided in the “Contact Information” section at the end of this Privacy Policy.
“Personal information” or “personal data” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information that is publicly available, a matter of public concern (such as newsworthy information), aggregated (e.g., compiled to create statistics that cannot identify a particular individual) or de-identified (stripped of all unique identifiers such that it cannot be linked to a particular individual) is not considered “personal information” for the purposes of this Privacy Policy.
We may collect or process various categories of personal information. The section titled “The Personal Information We Collect and How We Collect It” contains information on the categories of personal information collected. As an overview, depending on how you interact with us, we may collect identifiers and internet or other electronic network activity information. We collect this information to provide, maintain, and improve our Sites, and for other reasons listed in the “How We Use Your Personal Information” section below. Your personal information may be disclosed to service providers or other third parties as outlined in “How We Share Your Personal Information.” We will retain your personal information for as long as needed to fulfill the purposes for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not sell your personal information for monetary compensation, but we do partner with third-party advertising and analytics partners, which may be considered a “sale” of personal information under applicable laws. We do not collect sensitive personal information. We delete personal information in accordance with our data retention practices. If you would like to exercise your rights under applicable law, please visit the “Your State Privacy Rights” section of this Privacy Policy.
We collect the following personal information from you:
Identifiers: When you sign up for our newsletter, complete our “contact us” form, or create an account, we ask you for information such as:
Internet or other electronic network activity information:
We may use, and may allow certain third parties (including advertisers, third-party ad networks, and other ad companies) to use cookies, web beacons, and other similar online tracking technologies to provide our Sites, serve advertisements on the Sites, and to improve the performance of our advertising across the Internet.
Cookie providers, such as advertising companies, may gather personal information about your visit to the Sites or other websites to enable them to market products or services to you, to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. If you are based in a country or region which requires express consent for the use of certain kinds of cookies and of similar technologies and/or of information obtained by the use of cookies or similar technologies, we will comply with such consent requirements.
Depending on the particular advertising services they provide, third-party advertising companies may employ first-party cookies or third-party cookies. Unlike third-party cookies, first-party cookies are hosted on Cllct's servers.
The types of cookies used on our Sites can be categorized as follows:
Google Analytics: To help facilitate the delivery of relevant content, we use Google Analytics and Google Advertising. These services use cookies to report on user interactions on our and others’ websites. We use the information collected for optimizing marketing, refining advertising, and/or programming strategies, and generally improving user experience. For more information about Google Analytics and how it collects and processes information, please visit: https://policies.google.com/technologies/partner-sites. Instructions on opting out of Google Analytics using a specific plug-in is available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities and does not affect the activities of other ad networks or analytics providers that we may use.
If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Although this may provide you with enhanced anonymity, it may affect the functioning of our Sites. For example, blocking all cookies on the Sites may result in your browser not remembering log-in information or other preferences. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here or of companies participating in the Digital Advertising Alliance program by opting out here.
We may use the personal information we collect from you in the following ways:
We may share the personal information we collect from you in the following ways:
Our Sites may contain links to other websites owned and operated by third parties. After you leave our Sites, we have no control over the information collected from or about you on those third-party websites. These third parties may collect information from you when you interact directly with them. We are not responsible, and assume no liability, for the privacy policies and/or practices of any third party. The use of your information by third parties is subject to their privacy policies and terms of use. Accordingly, we encourage you to visit their sites and review their policies.
Please note that any information you post to any public posting area is available to anyone with Internet access worldwide. If you don't want people to know your email address, for example, don't include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.
The Sites may contain video content, audiovisual content, or content of a like nature (collectively,“Video Content”). In connection with our provision of Video Content, the Sites may utilize online tracking technologies and code-based tools, including, but not limited to, Software Development Kits (“SDKs”) and cookies (i.e., advertising or analytics cookies) that track information about your activity and webpage-viewing history on the Sites (collectively, “Tracking Tools”). Tracking Tools on the Sites may result in information about your activity on the Sites being transmitted from your browser to Cllct and third parties, which, in turn, may result in the display of targeted advertisements on third-party websites and platforms, including advertisements for Cllct content. In addition, whether Tracking Tools on the Sites results in your browser’s transmission of information to third parties depends on a number of factors that may be outside of Cllct’s knowledge or control, including what third-party websites you use, what information you have provided to such third parties, and whether (and the extent to which) you have limited the use of cookies by the operators of those third-party websites.
We may use session replay technology offered by third parties to monitor how you interact with our Sites. The personal information collected by this technology may include which links you click on, pages and content you view, information that you type into our online forms, recordings of mouse clicks and movements, and information about your device or browser. Please discontinue use of the Sites if you do not consent to the collection of such information by us and third parties.
The security of your personal information is important to us. We implement reasonable technical and organizational security measures to protect the personal information submitted to us, both during transmission and once it is received. Cllct takes steps to ensure that such data remains private and confidential. We restrict access to personal information to Cllct employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Sites. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission over the Internet. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach, we may attempt to notify you, including electronically, so that you can take appropriate protective steps. By using the Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Sites. We may post a notice via our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. If you have any questions about the security of your personal information, you can contact us via the contact information below.
We may retain your information for as long as needed to provide you with the Sites, comply with our legal obligations, resolve disputes, and enforce our agreements. In certain circumstances, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing access to the Sites.
Even if you delete your account, keep in mind that the deletion by our third-party providers may not be immediate, and that the deleted information may persist in backup copies for a reasonable period of time.
The Sites are hosted in the United States. In order to communicate with you about content, the information that we collect from you may be transferred to, stored, used, and processed by Cllct in the United States or one of our service providers based in the United States or outside of the United States. Such entities may be engaged in, among other things: (i) preparing and sending newsletters to which you subscribe and (ii) the provision of support services.
If you are visiting from the European Union or other regions with laws governing information collection and use that may differ from United States law, please note that you are transferring your personal information to the United States. The laws of some countries may not provide the same levels of protection of personal information as your home country, particularly if you are resident in the European Union. By using the Sites, you agree to the collection, transfer, storage, use and processing of information about you for the purposes described in this Privacy Policy. When you provide personal information to us or our service providers or vendors, you consent to the processing of your information in the United States as the Sites are operated in the United States. We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our service providers.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR PERSONAL INFORMATION WITH US, OR MAKE USE OF THE SITES.
The Sites are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If you are under 18, please do not use the Sites and do not provide any personal information to us. If you become aware that a child under 18 has provided us with personal information without your consent, please contact us at [insert method]. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting children’s privacy online.
At any time, you can add or remove your name from a Cllct list by contacting us at [insert method]. We will endeavor to comply with your request as soon as reasonably practicable. In certain circumstances, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing the Sites.
You may sign-up to receive email or newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us via the contact information below.
Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
Depending on applicable state law, you may have the right to object to our collection and use of your personal data at any time, or to require us to review, transmit, change, or delete the data that we have collected and retained about you. We will fulfill your request to exercise any of these rights within the applicable time period prescribed by such laws. You can exercise these rights, express concerns, or obtain additional information about the use of your personal data by contacting us as outlined below.
Specifically, residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia have certain rights with respect to their personal data, described in this chart. Below the chart we describe how residents of these states can exercise their rights and, where applicable, appeal our denial of a rights request.
| Description of Rights | Applicable to Residents of |
|---|---|
| Right to Know or AccessYou may have the right to obtain confirmation about whether or not your personal information is being processed by us. If so, you may have the right to access the personal information we hold about you and/or request other related information, such as the purposes for which use that information, the categories of personal information we process about you, the recipients (or categories of recipients) to whom your personal information has been or will be disclosed, the retention period for such personal information, or, if not possible, the criteria used to determine that period, your legal rights with respect to your personal information, etc. | California, Colorado, Connecticut, Utah, Virginia, Texas, Montana, Oregon |
| Right to Delete You may have the right to request the deletion of your personal information, except under certain circumstances subject to applicable law. | California, Colorado, Connecticut, Utah, Virginia, Texas, Montana, Oregon |
| Right to Correct Depending on your location and applicable laws, you may have the right to correct or update your personal information if inaccurate. | California, Colorado, Connecticut, Virginia, Texas, Montana, Oregon |
| Right to Opt-out of Sale, Sharing, and Targed Advertising of your Personal Information You may have the right to opt-out of the sale of your personal information to third parties. You may also have the right to opt out of the processing of your personal information for the purposes of targeted advertising. | California, Colorado, Connecticut, Virginia, Texas, Montana, Oregon |
| Right to Revoke or Withdraw ConsentYou may have the right to withdraw consent to the continued use or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice. | California, Colorado, Connecticut |
| Right to NondiscriminationYou may have the right to non-discrimination, such as to receive equal service from a business, even after exercising your rights. | California, Colorado, Connecticut, Utah, Virginia, Texas, Montana, Oregon |
| Right to Data PortabilityDepending on your location and applicable laws, you may have the right to receive the personal information that you have given us and that we are processing, in a structured, commonly used and machine-readable format. You may also have the right to send that personal information to another controller. | California, Colorado, Connecticut, Utah, Virginia, Texas, Montana, Oregon |
| Right to Opt-out of ProfilingYou may have the right not to be subject to a decision based solely on profiling or automated decision-making. | California, Colorado, Connecticut, Virginia, Texas, Montana, Oregon |
| Right to Obtain a List of Relevant Third PartiesYou may have the right to obtain from us, at our option, a list of specific third parties, other than natural persons, to which we have disclosed your personal information, or any personal data. | Oregon |
To exercise any of the above rights, please submit a verifiable consumer privacy request to Cllct:
We cannot respond to your request or provide you with personal information unless we can verify your identity and your authority to make the request and confirm that the personal information relates to you. A verifiable consumer privacy request must:
If you are a resident of California, Colorado, or Connecticut, you may, under certain circumstances, authorize another individual or a business, called an Authorized Agent, to make requests on your behalf. If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
We do not charge a fee to process or respond to your verifiable consumer privacy 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.
Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, and Virginia have the right to appeal a denial of their request by contacting us as described in our notice of denial.
In order to provide you with more personalized and relevant content, we work with third party advertising and analytics partners, which may be considered a "sale” or “sharing” as those terms are defined under applicable privacy laws, such as the California Consumer Privacy Act. The personal information we “sell” or “share” is limited to your identifiers and internet or other electronic network activity information. At any time, you can opt out of the sale or sharing of your personal information by completing the webform located at [insert link to “Do Not Sell or Share” webform].
A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal information if it shares such information with third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.
Residents of Nevada have the right to opt out of the sale of certain personal information to third parties. We currently do not sell your personal information as defined by Nevada law.
We process personal data as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”) and the equivalent UK law. If you are located in the EEA, U.K., or Switzerland, you have the following rights:
In processing personal data, we may rely upon the following lawful bases:
Users who are located in the European Economic Area (“EEA”), the European Union, the U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the relevant supervisory authority in their country of residence. Contact details for data protection authorities are available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you would like to exercise any of these rights, please contact us at the information provided below.
We may need to update this policy from time to time, and we reserve the right to do so as we deem necessary or desirable. We will notify you of such changes by revising the “Effective Date” provided herein, and/or by any other legal means, and your use of the Sites after any such changes shall constitute your consent to such changes. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have questions or concerns about our Privacy Policy or our privacy practices, please contact us:
Email: biz@cllct.com
Mail: 1501 Broadway, Suite 3100, New York, NY 10036