- Why does TDMG collect personal information?
- From whom does TDMG collect consumer data?
- What information does TDMG gather or track?
- What are Cookies?
- Does TDMG disclose user information to third parties?
- Can I opt-out of TDMG’s data collection and/or distribution?
- What about external web sites?
- What does TDMG do to keep their site secure?
- Does TDMG collect information from users outside of the United States?
- Does TDMG collect personal information from children?
- What about TDMG's offline information and privacy practices?
- What are my Nevada rights?
- What are my California rights?
1. Why does TDMG collect personal information?
We need to collect certain personal information from our customers and visitors primarily to process their sweepstakes entries and magazine orders for the products and services we offer. For example, we need your full name, full address, e-mail address, and telephone number to verify eligibility and enter you in the sweepstakes, notify you if you've won a prize and to send you any products and/or services you may purchase. We may also use the personal data we collect for systems administration and troubleshooting purposes, and to report aggregate information to our partners and others. To provide our users with a more personalized and relevant web service, we also collect and use personal data to identify users' specific interests and needs. If given permission, we may notify our users of offers and information we feel may be of interest to them available from our partners. If given permission, we may also share information with our select partners who may directly contact our users regarding their own offers of interest.
Your email will only be shared with our preferred mailing partner for the purposes of sending third party promotional email communication.
Providing Customer Service may be another reason to collect personal information, in order to communicate to you via SMS / email / direct mail / phone about your entries, orders, payments, and any other question you might have.
We may share our unsubscribe list with our select partners for the sole purpose of insuring that individuals on this list do not receive electronic commercial mail messages containing ThinkDirect Marketing Group advertisements that may be sent by such partner. If you are currently receiving commercial e-mail messages from TDMG after previously providing permission and no longer wish to receive such offers you may always follow the unsubscribe procedures which will be found within the commercial e-mails received from TDMG. From time to time, we post customer testimonials on our web site which may contain personally identifiable information such as the customer's name. We do obtain the customer's consent prior to posting these testimonials.
2. From whom does TDMG collect consumer data?
Directly from the Consumer: The information you provide us directly when registering on our website (e.g., name and address), claiming prizes, and entering into the Sweepstakes.
Integrated data collection: when you visit our website, information such as your IP address, device ID, browser type, internet service provider, operating system, date/time stamp and through the use of “cookies” or “Pixel tags”, through similar tracking technologies.
Third party sources: we also obtain data from third party platforms, advertisers, publishers, as well as commercial data aggregators who collect data from businesses and other sources and make that data available to commercial users like TDMG for a valuable consideration, or through coops and exchanges in which third party operators pool their consumer data and make it available to others in the coop or exchange.
3. What information does TDMG gather or track?
TDMG collects data from our consumers in the following categories:
- Identifying information: mainly during the initial registration process for sweepstakes entry and order
- Demographic Data: We may collect information such as geographic area, gender, age, entry date, and sweepstakes winners and payout preferences.
- Technical Data: We may collect site traffic data such as your IP address, Mobile Advertising ID, and data on the website that may have referred you to us.
- Interest/Affinity Data: Information about your hobbies, products you’ve subscribed to and payments made.
- Winner Information Data: Information may be collected for the sweepstakes you’ve entered, prized you’ve won, and payment preferences.
Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas on the site will not function properly if your web browser does not accept cookies. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
5. Does TDMG disclose user information to third parties?
Except as otherwise noted in this policy, TDMG only discloses user information in aggregate form to partners. For example, we might tell a partner how many users visited TDMG websites over a period of time, but we will never tell them who it was, unless that user has given us permission to do so.
TDMG believes that consumers should be able to control the use of their data. We will not share personally identifiable information with partners if you follow the simple unsubscribe procedure. If an opt-out is not submitted, we will notify users of exciting offers of interest from TDMG and our partners. We may also share your name, land address, e-mail address and telephone number with our partners so that they can send you offers directly for products and services that may be of interest to you. The personal information our users provide to us may be combined with other personally identifiable information (such as demographic information and past purchase information) available from our records and other sources. We use a third party to verify your address, in order to process your order prior to shipping. This allows us and our partners, with permission, to present our users with offers and information geared towards their interests.
We require each permission based e-mail our partner sends to include a description of a simple opt-out process that will enable you to stop receiving promotional e-mail from them in the future. Nevertheless, TDMG is not and cannot be responsible for the activities or privacy policies of these third parties. We may share our unsubscribe list with our select partners for the sole purpose of insuring that individuals on this list do not receive electronic commercial mail messages containing TDMG advertisements that may be sent by such partner.
We do not rent, license, or sell personal data to third parties unless permission is granted. In the event of a merger, acquisition, or change of control of TDMG, customer data would be considered a business asset and would be transferred. We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We may also disclose personal information as required by law or to protect the safety and security of our users.
Marketing Partners who wish to target and/or retarget our Users with relevant advertisements or products, and magazine publishers or direct-to-consumer merchants who wish to communicate directly with our customers and users through name rental or exchange.
We use other third parties such as credit card processors and e-mail service providers to provide order fulfillment and e-mail delivery services on our site. When you register on our site, we will share your personally identifiable information as necessary for these third parties to provide these services.
These third parties are prohibited from using your personally identifiable information for any other purpose including their own marketing purposes.
6. Can I opt-out of TDMG’s data collection and/or distribution?
Receiving email messages from TDMG, our affiliates and partners is optional. As noted earlier, the collection, use, and distribution of personal data helps us create a more personalized, relevant, and intelligent web service for our users. While some basic data is necessary to provide certain services, such as entry into the sweepstakes and fulfillment of products and services ordered through TDMG, there are some cases where the submission of information is optional.
We will not contact you with e-mail offers or share personally identifiable information with our partners if you follow the simple opt-out procedure. If you are already receiving TDMG emails and no longer wish to receive such communications, simply follow the "unsubscribe" instructions that appear in every TDMG e-mail.
7. What about external web sites?
8. What does TDMG do to keep their site secure?
We have implemented a number of security features throughout TDMG sites that are intended to prevent the unauthorized release of or access to the user information we collect online. For example, database information is firewall protected. Also, only authorized TDMG personnel have access to any stored personal information we collect from our users. Moreover, password and credit card information you submit to TDMG is always encrypted during transmission. Users should be aware that e-mail is not encrypted and is not considered a secure means of transmitting credit card numbers.
While we strive to create a secure and reliable site for our users, the confidentiality of any communication or material transmitted over the Internet cannot be 100% guaranteed. Users should keep in mind that any information submitted through an Internet transaction is potentially accessible to the public, and consequently, can be collected and used by others without their consent. TDMG is not responsible or liable for illegal interception of personal data via any Internet transaction. When we collect and transmit sensitive data such as your credit card number, we encrypt it using secure socket layer technology (SSL).
9. Does TDMG collect information from users outside of the United States?
TDMG sites are not directed to visitors residing outside of the United States. However, as indicated in the Official Rules on the site, some sweepstakes promoted on TDMG sites are open to residents of the 50 United States, the District of Columbia, Puerto Rico (excluding other U.S. territories and possessions), and Canada (except for the province of Quebec). Residents from these countries can participate in these sweepstakes by registering online. We regret that as a result of system limitations at this time non-U.S. residents may not order products or services through TDMG.
10. Does TDMG collect personal information from children?
The TDMG sites are not targeted nor directed to children under the age of eighteen. TDMG does not intend to collect personally identifiable information from individuals in this age group. If TDMG receives actual notice that a child under the age of eighteen has provided personal information to TDMG, we will use reasonable efforts to remove such information from its files.
11. What about TDMG's offline information and privacy practices?
ThinkDirect Marketing Group collects certain personal information from our direct mail customers and entrants primarily to process sweepstakes entries and fulfill orders for the products and services we offer. For example, we need your full name, full address and telephone number to enter you in the sweepstakes, notify you if you've won a prize or to send you any magazine subscription or product or service you may purchase. We may also use the personal data we collect for systems administration and troubleshooting purposes, and to report aggregate information to our partners and other third parties. From time to time we may share or exchange marketing information about the consumers who respond to our offers with other companies so they may contact you about products and services that may interest you.
If you do not want your name passed on to other companies for the purpose of receiving marketing offers, please contact us at 1-800-690-3623 and we will be pleased to respect your wishes. Please make sure to provide your full name, address, city, state and zip code information.
12. What are my Nevada rights?
Under Nevada law, consumers that reside in Nevada have the right to make a verifiable request prohibiting us from selling “covered information” that we have collected or will collect to a third party (“Verifiable Opt-Out Request”). “Covered Information” may include your first name and last name; a home or other physical address; and email address; a social security number; an identifier that allows for a person to be contacted either physically or online; or any other information concerning a person collected from the person through the Site and maintained in combination with an identifier that makes the information personally identifiable. We may not be required to follow a consumer’s Nevada Opt-Out Request under specific circumstances.
If you are a Nevada consumer and would like to make a Verifiable Opt-Out Request, please email us email@example.com. We intend to respond to Verifiable Opt-Out Requests within 60 days. If we need more time to respond to a Verifiable Opt-Out Request, we will notify you of such an extension.
13. What are my California Privacy rights?
Information We Collect
We collect the following categories of personal information as described in the “How and what information does TDMG gather or track?” section #2 above:
- Identifiers, such as name, email address, mailing address, cookie and device identifiers, and IP address
- Demographic information, such as your gender and age
- Internet or other electronic network activity information, such as log data and information about the devices and computers you use to access TDMG websites
- Electronic, visual, or similar information, such as photos that you may provide voluntarily
- Other information you provide, such as responses to surveys or messages to customer service
- Inferences drawn from any of the above, including about the content or ads that may be of interest to you
We collect this personal information from you, your devices, third parties, and from the following categories of sources:
- Directly from you
- Indirectly from you. For example, through information we collect from our clients in the course of providing services to them
- Directly and indirectly from activity on our website
- From third-parties that interact with us in connection with the services we perform
How We Use Personal Information
We use these categories of personal information as described in the "Why does TDMG collect personal information?" section above. In addition, we use personal information in the following ways:
- To fulfill your requests for products, services, or information
- To process your payments and ship your products
- To provide technical and other support, including to understand and resolve technical issues with the website
- To verify eligibility and enter you in the sweepstakes, contests or promotions
- To notify you if you've won a prize
- For testing, research, analysis and product development
Sharing Personal Information
We disclose these categories of personal information for the business purposes described in the "Does TDMG disclose user information to third parties? " section above. In addition, we disclose information for business purposes to the following entities:
- Service providers
- Our affiliates
- Other individuals, services, and partners at your request
- Contests and promotions partners
- Social media networks
- Entities for legal purposes
- Entities for sales or transfer of business or assets
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Access to Specific Information, Data Portability and Deletion Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. As a California Consumer, you also have the right to make a verifiable request that We delete any personal information about you which we have collected or maintained.
The CCPA allows you to request us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share/disclose personal information
- Provide access to and/or a copy of certain personal information we hold about you
- Delete certain personal information we have about you
- Provide you with information about the financial incentives that we offer to you, if any
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.
Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, e-mail address, and physical address.
You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
If you would like further information regarding your legal rights under California law or would like to exercise any of them, please submit your request as outlined on the following page:CCPA - California Residents
If you prefer, you may submit a verifiable consumer request to us by one of the following methods:
- Calling us at 1-800-690-3623
- By email at firstname.lastname@example.org with the subject line: "CCPA Request"
- By writing us at: ThinkDirect Marketing Group PO Box 9084 Clearwater, Florida 33758
Notice of Right to Opt-Out of Sale of Personal Information
California residents may opt out of the “sale” of their personal information. Under the CCPA, “sale” is broadly defined to mean the sharing of personal information with third parties, in exchange for valuable consideration, who are not acting as our service providers or who are otherwise not restricted from using data only on our behalf or pursuant to an applicable CCPA exception.In some circumstances, we may share certain of your information with third parties to provide you with offers, promotions, and opportunities that may be of interest to you, which may be considered a “sale” under the CCPA.
Under the CCPA, “sale” may also include allowing third parties to “collect” certain information, such as IP address, and/or browsing behavior, through cookies and similar technologies, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information. Please note that we do not knowingly sell the personal information of minors under 18 years of age without legally-required affirmative authorization.
Right to Non-Discrimination for the Exercise of Your Privacy Rights
We cannot discriminate against you because you exercised your rights under the CCPA. You have a right not to receive discriminatory treatment from ThinkDirect Marketing Group for the exercise of your privacy rights conferred by the CCPAChanges to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will update the Policy last updated date as noted on the bottom of this page
- Postal Address: ThinkDirect Marketing Group PO Box 9084 Clearwater, Florida 33758
- You can reach us by telephone at 1-800-690-3623.
- Or you can reach us by email: email@example.com
1. Collection of Personal Information
National Magazine Exchange (“the Company”) collects certain Personal Information. (“PI”). The PI that we may collect includes only the visitor’s domain name and information volunteered by visitors, such as names, postal addresses, telephone numbers, and dates of birth.
2. Use of Personal Information
We may use your PI and other information we collect about you for lawful purposes only. Such uses may include, without limitation, use of your PI to:
- operate and improve our other products or services;
- understand you and your preferences for purposes such as to enhance your experience and enjoyment of our other products and services;
- process and deliver promotional (e.g., contests and sweepstakes) entries and rewards;
- send you a welcoming email;
- provide the services, products or information you request and to process payments and complete any transactions in connection therewith;
- respond to your comments and questions and provide customer service;
- provide and deliver products and services you request;
- request feedback and to enable us to develop, customize and improve our other products and services;
- send you surveys or questionnaires;
- send you newsletters you have requested;
- send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- communicate with you about new contests and sweepstakes, promotions and rewards, upcoming events, and other news about products and services offered by Company and our selected partners;
- for editorial purposes, such as to contact you about content you have submitted to give attribution to content you submit;
- link or combine with other personal information we get offline and/or from third parties lawfully, for purposes such as to help understand your needs, provide you with better service, and determine whether marketing offers from third parties would be of interest to you; and
- investigate and take action against fraudulent or illegal activity or improper conduct and otherwise protect us and our users.
3. Sharing of Personal Information
We may share your PI for lawful purposes. For example:
We may share your PI with our technical consultants, auditors and other third parties who act on our behalf, to enhance functionality, or to provide services related to the fulfillment of subscriptions or orders for any of our publications or other products and services (such as sending emails, processing credit cards, fulfilling subscriptions and other orders, providing customer service, and performing data-, information technology services-, or marketing-related services), and/or who assist us in producing, delivering, billing, collecting payments
4. Cookies, Web Beacons and Server Logs
We and third parties such as web hosting providers with whom we have contractual arrangements, advertisers and ad serving and tracking companies, sometimes utilize “cookie” technology and other tracking technologies now and hereafter developed (“Tracking Technologies”) on or in connection with our sites. Cookies are bits of data stored on your hard drive that contain no personally identifying information (but may associate a unique identifier with your device and/or collect information that is hashed or otherwise converted to non-PI). Not all Web browsers accept cookies, and those that do usually provide a preference or setting that allows you to refuse and remove most types of browser cookies. If your browser does not accept cookies, you may still enjoy the Service but not all features and functionality may work.
We may collect information using web beacons. Web beacons are electronic images that may be used on our sites or in our emails. We may use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, collect and share information that is converted to non-PI, and to tell if an email has been opened and acted upon.
Server logs capture certain non-personally identifying data (but do track device identifiers), such as the time and date of a Web visit or opening an email, the browser and operating system being used, and the Web URL a user linked from. This information may be used for various purposes, such as use in aggregate form to help us plan system enhancements when necessary and to provide content that is compatible with our visitors’ Web-browsing systems. We also collect information about keyword searches performed by visitors on the Website. We do not collect your name or email address as a result of using a search feature. We may keep logs of all words searched to help us learn what kinds of information Website visitors are seeking, and to improve our Website.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites, we currently do not alter our practices when the Website receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies, such as is described above regarding analytics and Interest-based Advertising.
5. Third Party Advertising and Analytics
6. Privacy and Security Precaution Warning
Please note that no data transmission over the Internet is 100% secure. As a result, we cannot guarantee the security of the information that you transmit via the Service.
We reserve the right, at our discretion, to prospectively change, modify, add, or remove portions of this policy at any time. Please bookmark this page and check it periodically. We will post any changes online.
Policy last updated: May 28, 2020