This Policy is aligned with PRDMOs internal practices and does not in any way clash with any other policies adopted and prepared by PRDMO.
For the purposes of this Policy, the term “user” will encompass any individual, whether a registered or non-registered user, that enters and/or visits the PRDMO’s Webpage.
EFFECTIVE DATE AND CHANGES TO BE NOTIFIED
This Policy is in effect as of [4/30/2020]. If this Policy were to be modified either partially or in its entirety, all PRDMO users who have provided PRDMO with their email address will be immediately notified via email of such notification. Users that do not provide PRDMO with an email address will be able to access the new Policy upon entering PRDMO’s Webpage.
TYPE OF INFORMATION COLLECTED
Personally Identifiable Information (“PII”): This is to be construed as information that allows for the identification of an individual. This information includes, but is not limited to, the following: first and last name(s); workplace address; mobile number; home phone number; work phone number; personal email address and work email address.
Non-Personal Identifiable Information (“NPII”): This is to be construed as information that does not easily permit the identification of an individual and that once PII elements are removed, hinder an individual’s personal identification. This information includes, but is not limited to, the following: content preferences; travel preferences, and network traffic data.
PURPOSE FOR COLLECTING THE INFORMATION AND WHO WE SHARE IT WITH
All information voluntarily provided by PRDMO users is obtained in order to: (1) confirm the user’s identity and contact information; (2) coordinate marketing endeavors; (3) answer any questions the user may have regarding PRDMO; (4) if the user wishes to do so, create a partner log-in; (5) data collection; (6) provide users with industry updates, meeting minutes and notices, monthly reports, research updates, and additional marketing materials.
Users may opt-out from receiving PRDMO related communications and marketing materials at any time. In order to Opt-out, users must email PRDMO at the following address firstname.lastname@example.org to “unsubscribe” to received emails.
Moreover, PRDMO does not by any means sell, distribute, lease, license or share its users PII, NPII or any other user related information to a Third-Party, other than those subcontracted by PRDMO, or to any other individual or entity that requests a user’s personal information. However, PRDMO may share or disclose its users or client’s information if the following circumstances were to arise:
- A governmental, law enforcement or national security agency requests the information pursuant to a statutory requirement or court order.
- Prior to the handing over of the requested information to the aforementioned agencies, PRDMO’s legal team will verify that the request complies with the corresponding applicable laws.
- A PRDMO client or user consents and allows for their information to be disclosed to a specific Third-Party, individual or entity;
- An emergency situation were to arise wherein property or life were at risk.
- Under this scenario, PRDMO would provide the necessary information to the individuals, entities, and/or legal authorities that may need this information. This disclosure will be done in accordance with federal and Puerto Rico law as well as any privacy laws applicable to PRDMO Webpage users that are not under the jurisdiction of the United States of America or Puerto Rico.
WHEN DO WE COLLECT THE INFORMATION
Generally, PRDMO’s Webpage collects a user’s personal information whenever it is voluntarily provided. Specifically, the PRDMO Webpage collects user’s personal information in the following instances:
- Under the “Contact Us” field;
- When the user chooses to create a partner login and register to access PRDMO’s media vault and DMO private documents; and
- When the user directly calls (787-710-8280), emails (email@example.com), or visits the PRDMO offices (500 Calle de la Tanca Building Ochoa, Suite 402B, San Juan, PR 00901) and speaks to a PRDMO representative or agent.
PRDMO maintains PII and NPII for as long as need be in order to fulfill the purpose for which the information was collected, and assure compliance with any legal, accounting, or reporting requirements.
In addition to PRDMO employees, PRDMO subcontractors will have access to the user’s personal information to the extent necessary in order to send out marketing materials that the user has voluntarily signed up for. The number of PRDMO employees and subcontractors is limited and adheres to confidentiality and security protocols established by PRDMO to safeguard all personal information. These confidentiality and security protocols fall within the scope of federal and Puerto Rico law as well as any privacy laws applicable to PRDMO Webpage users that are not under the jurisdiction of the United States of America or Puerto Rico.
PRDMO’s Webpage complies with applicable federal law and Puerto Rico law. Moreover, because PRDMO’s Webpage will be visited by users that do not fall under the jurisdiction of the United States of America or Puerto Rico, this Policy also complies with the minimum requirements imposed by other privacy laws including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
PRDMO’s Webpage is not intended to be used by minors under the age of 13. In accordance with the Children Online Privacy Protection Act of 1998, 15 U.S.C. §§ 6501-6506 (“COPPA”), PRDMO hereby reiterates that it does not knowingly or consciously maintain, collect, request or disclose PII, NPII, or any other information related to children under the age of 13.
If any of the dispositions contained in this Policy were to be declared null and void, only those dispositions will be eliminated while the rest of the Policy will remain in effect.
CORRECTIONS AND CONTACT INFORMATION
If any doubts or concerns were to arise regarding this Policy, if you believe that any of the PII or NPII that you have provided to PRDMO contain any errors, or you simply wish to alter the information provided, please do not hesitate to contact Liz Mabe in order to rectify the issue and answer any questions or concerns.
787-710-8280; firstname.lastname@example.org; and Monday-Friday 8:30am-5:30pm.
Effective Date: April 30, 2020