Table of contents:
- What information we collect, why we collect it, and how it is used;
- How we protect and store your information;
- How we share your Personal Information
- Transferring Personal Information
- The legal basis for using your Personal Information
- Your rights
- Direct marketing and how you can manage your preferences
- Use by children
- How to contact us
What information we collect, why we collect it, and how it is used
We collect information on our Website and/or our Platforms that can identify a User or may, with reasonable efforts, cause the identification of a User (“Personal Information”) when you:
- Request to try and/or use our products and services;
- When you submit your resume for one of the positions offered on our Website; and/or
- Commence direct communications with us either in relation to a query or complaint.
- Subscribe to receive marketing materials from us.
- Register to an MMR event.
1/ Request to try and/or use our products and services. We will ask you to provide us with Personal Information as described above for the purposes of creating a User account, when you choose to try our products and services (“Account”). When opening an Account, providing us with the following Personal Information is mandatory: your first and last name, and your email address. When using our Platforms, we will also collect your Personal Information from social media platforms such as Facebook, including your Facebook access token, Facebook ID, name and email.
During the process of creating an Account, you can choose to share with us additional information (which may also be considered Personal Information) such as your work/home phone number, job title, and place of residence.
2/ Commencing direct communications with us. We collect Personal Information when you commence direct communications with us, for example via our Website inquiry form, by telephone or writing to us. When you commence direct communications with us, we will retain such communication(s) and the accompanying Personal Information for the amount of time necessary to adequately and professionally process your inquiries, respond to your requests and improve our services to our Users. When commencing a communication with us, we will usually collect your first and last name, email address, and any additional information you may choose to provide.
3/ Submitting your resume. We collect your Personal Information when you submit your resume via http://info.makemereach.com/career, such as your name, email, phone number, the content of your resume and any other information you choose to share with us, in order to properly process your application, and contact you should a position be relevant for you.
4/ Subscribe to receive marketing materials from us. When you consent to us sending you marketing materials, for example our newsletter or blog digest, we will collect your Personal Information, such as first name, last name, work email, phone number, job title, and average amount spent per month on social media.
5/ Register to an MMR event. We collect Personal Information such as your first and last name, and email address when you register to an event we post on our Website.
6/ Collection of non-personal, Statistical Information. When browsing through our Website, we will collect non-personal, aggregate information about your interaction with our Website, including pages browsed, search inquiries, the type of browser you are using, non-identifiable cookies and your domain type and server ( and collectively, “Statistical Information”). We collect this type of Statistical Information in order to analyze and improve User’s use of the Website, customer support, sales intelligence and for debugging purposes.
How we protect and store your information
In some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
How we share your personal information
10/ In addition, we will share some (or all) of your Personal Information in the manner and for the purposes described below:
- With third parties who help manage our business and deliver services (i.e., our subcontractors). These third parties have agreed to confidentiality restrictions, as well as complying with applicable privacy and data protection laws, and will use any Personal Information we share with them solely for the purpose of providing the contracted service(s) to us. You can find list of our sub-processors under that link.
- To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
- If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets.
Information regarding transfers of personal information
11/ We ensure transfers within the MMR/PERION group will be covered by an agreement entered into by members of the MMR group (an intra-group agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to;
- where we transfer your Personal Information outside of MMR, for example to third parties who help provide our products and services (described in Section 8), we will obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States; or
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
The legal basis for using your personal information
12/ We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. Such legal basis’ include :
- our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, for example for the purpose of providing you with our services, processing your resume, creating your user account, registering to an MMR event, or communicating with you in relation to a query or complaint);
- you have provided your consent to us using the Personal Information (e.g., where you provide us with consents or opt-in to receive marketing materials and/or optional additional services or functionalities);
- our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g., the disclosure of information to law enforcement or tax authorities).
13/ If you would like to find out more about the legal basis for which we process Personal Information please contact us.
14/ The following rights (which may be subject to certain exemptions or derogations), shall apply in addition to the above to users of the Website and/or our Platforms who are protected by the GDPR:
- You have a right to access information held about you. Your right of access is normally exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to revise your Personal Information by editing your Account details, or request that we amend any Personal Information we hold that it is inaccurate or misleading.
- You have the right to request the erasure of the Personal Information that relates to you. Please note that there may be circumstances in which we are required to retain your data for the establishment, exercise or defense of legal claims;
- The right to object to or to request restriction of the processing. Again, there may be circumstances in which we are legally entitled to refuse your request;
- The right to data portability. This means that you have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
- The right to withdraw your consent. Again, there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
- You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
15/ You can exercise your rights by contacting us via email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
16/ In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
Direct Marketing and how you can manage your preferences
17/ We may use your Personal Information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
18/ For the purpose of protecting your privacy and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively you can contact us at firstname.lastname@example.org. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email); and
- you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below.
19/ Our Website uses certain monitoring and tracking technologies (such as cookies).
20/ A cookie is a small text file that is stored in a web browser directory by a website or an advertisement related action. Our Website uses two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your web browser directory while you are visiting a website and are deleted once you leave the website. Persistent cookies remain in your web browser and are activated again once you visit the website that created that specific cookie.
22/ We will not use the above technologies to collect Personal Information without obtaining your permission, unless where we are permitted to do so under applicable privacy laws.
23/ Please note that your browser enables you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Website or other internet websites.
24/ If you would like to opt-out of the non-personally identifying cookies that our Website may use, please email us at email@example.com.
25/ If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the "opt out" cookie, you will need to perform this opt-out process again upon any such change.
26/ For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.
Use by children
27/ We do not offer our products or services for use by children. If you are under 18, you may not use the Website and/or our Platforms, or provide any information to the Website and/or our Platforms without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
28/ If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org.