Last Updated: May 24, 2018
Poemhunter.com. and its subsidiaries (“Poemhunter”), respect your concerns about privacy. References in this Privacy Policy to “Poemhunter”, “we”, “us”, and “our” are references to the Poemhunter entity responsible for the processing of your personal information, which generally is the Poemhunter entity that collects your personal information.
This Privacy Policy describes the types of personal information we obtain, how we may use that personal information, with whom we may share it and how you may exercise your rights regarding our processing of that information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.
This Privacy Policy applies to the personal information we obtain through Poemhunter properties, including websites, desktop and mobile apps, and other tools offered by Poemhunter that reference this Privacy Policy (“Online Channels”); offline collection, including Poemhunter events, surveys, questionnaires, customer user research and evaluations (“Offline Channels”); and third-party sources, including business partners, ad networks (collectively, the “Offerings”). This Privacy Policy does not apply to other Poemhunter products and services that post separate privacy policies.
The Online Channels may provide links to other third-party websites and features. Some of these third-party websites may be co-branded with a Poemhunter logo even though they are not owned, controlled, operated or maintained by Poemhunter. Poemhunter does not share your personal information with those websites and is not responsible for their privacy practices. These websites are subject to their respective privacy policies. In some cases, we may provide the Offerings jointly with other businesses. For these co-branded offerings in which a third party is involved in your transactions, we will sometimes share or jointly collect customer data related to those transactions with that third party.
The data we obtain varies based on the offerings you use. We obtain personal information through your interaction with the offerings, such as when you:
The types of personal information we obtain include:
contact information (such as name email address, telephone number, postal or other physical address) for you;
Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.
We use the information we obtain to:
Depending on the purposes for which personal information is used, and the context in which the data is obtained, we may rely on one or more of the following legal bases:
We may combine data collected from you with other sources to help us improve the accuracy of our marketing and communications as well as to help expand or tailor our interactions with you. This includes combining personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information (such as referral programs), for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.
Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
Poemhunter uses cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels that collect certain information about you by automated means. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Offerings, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).
The cookies we use on our Online Channels include (1) essential and functional cookies; (2) analytics cookies; and (3) targeting/advertising cookies, as described below.
We use cookies on our Online Channels that are necessary for us to provide you with our products and services. This includes essential cookies (such as those used to authenticate you to our website and identify you after you have logged in), functional cookies (such as those that the language preference you selected), and user-centric security cookies used to increase the security of the products and services we provide to you (such as to detect authentication abuses). Given the necessary functionality of these cookies, they typically may not be disabled on our Online Services.
Advertising cookies are used to control and manage advertisements. These Cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us to offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EU, we deploy analytics and advertising cookies on our websites only when users have opted-in as required by applicable law.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.
The providers of third-party apps, tools, widgets and plug-ins on our Online Channels (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Poemhunter is not responsible for these providers’ information practices.
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites (such as on websites that serve our ads). We may use such information to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks. Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve Poemhutner advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
We do not sell or otherwise disclose personal information about you except as described here or at the time of collection. Poemhunter may share personal data in the following ways:
We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss to Poemhunter, its users or the public as required or permitted by law, (4) to establish, exercise or defend our legal rights, and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues.
In addition, we reserve the right to transfer to relevant third parties information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business transaction.
We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
We transfer the personal information we collect through the Channels to, and store such data in, other countries in which Poemhunter and its service providers operate, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the General Data Protection Regulation (GDPR), or by selecting data recipients that are certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks described below.
With respect to transfers of personal information from the EU and Switzerland to the U.S., Poemhunter is certified under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and the European Commission regarding the transfer of personal information from the EU to the U.S., pursuant to article 45 of the GDPR (each a “Privacy Shield Framework” and collectively the “Privacy Shield Principles”). If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program please visit https://www.privacyshield.gov/.
Poemhunter is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Poemhunter complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to a Privacy Shield Framework, Poemhunter is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Poemhunter may be required to disclose personal information in response to lawful requests by public authorities, including to satisfy national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
In compliance with the Privacy Shield Principles, Poemhunter commits to resolve complaints about our collection or use of your personal information. If you have questions or complaints regarding our Privacy Policy or practices, please contact us here.
EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Poemhunter here. If you have an unresolved compliant that has not been addressed to your satisfaction, please contact or visit https://feedback-form.truste.com/watchdog/request (a U.S.-based alternative dispute resolution provider) for more information or to file a complaint. The services are provided at no cost to you.
Poemhunter has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
We offer you certain choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you. To update your preferences, limit the communications you receive from us or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Policy. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend or delete your information, or that we restrict the processing of such information by contacting us as indicated below or by accessing your account. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.
We support the Self-Regulatory Principles for Online Behavioral Advertising ("Principles") to find a convenient place to indicate your preferences, including the option to make one "universal" opt-out of interest-based advertising with participating entities. Advertising websites also provide detailed information about interest-based advertising and tips for managing your privacy online and in applications. Opting out of interest-based advertising does not mean you will no longer see advertisements from us or on the Online Channels; rather, opting out means that the online ads that you do see will not be based on your interests. When you opt-out of receiving interest-based advertisements through the links above, cookies and other technologies on the Online Channels may still collect information about your use of the Online Channels, including for analytics, fraud prevention and any other purpose permitted under the Self- Regulatory Principles.
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked.
Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.
To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it, in accordance with the terms of this Privacy Policy, which generally means that we will keep your personal information for the duration of our relationship or as long as you keep your account open with us; or (2) to take into account applicable statute of limitation periods and comply with applicable laws, resolve disputes and enforce our agreements. As described in the “Your Rights and Choices” section above, to the extent provided by the law of your jurisdiction, you may request that we delete your information or restrict the processing of such information by contacting us as indicated below.
Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send an email to privacy@poemhunter.com with "California Shine the Light Privacy Request" in the subject line and in the body of your message.
The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us here or by email at privacy@poemhunter.com.