Marden-Kane, Inc. and its wholly-owned subsidiary, Bolt Apps (“Marden-Kane”, “We”, “Us”) have created this statement in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and dissemination practices for our website, www.mardenkane.com and for our company in serving our clients. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

If you have questions or complaints regarding our privacy policy or practices, please contact us at expert@mardenkane.com.

Marden-Kane, Inc. complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland to the United States, respectively. Marden-Kane Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Marden-Kane, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Marden-Kane, Inc.at: expert@mardenkane.com.

The Federal Trade Commission has jurisdiction over Marden-Kane, Inc.’s compliance with the Privacy Shield.

Marden-Kane, Inc. has further committed to refer unresolved privacy complaints under the EU-US and Swiss Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Under certain limited conditions, individuals may invoke binding arbitration as a last resort before the Privacy Shield Panel.

Marden-Kane Promotions

As a full service promotional marketing agency, Marden-Kane operates Promotions on behalf of its clients. As part of those services, Marden-Kane receives, collects, stores and processes personally identifiable information of consumers on behalf of its clients by use of both online and offline technologies. Such uses may include notification of potential winners, fulfillment of prizes, client email list generation and marketing analysis. Marden-Kane strictly limits access to all personally identifiable information within its organization, and data is never shared outside of the company for any reason whatsoever (with, of course, the exception of the Promotion client, appropriate governmental or legal requests). Personally identifiable information collected by Marden-Kane on behalf of a client belongs solely to the client and will be used solely in accordance with that particular client’s Privacy Policy. An individual’s desire to “opt-out” of receiving marketing or other information from a client will be handled in accordance with a particular client’s Privacy Policy and should be directed to that client or Sponsor of the Promotion. Marden-Kane requires its clients, by contract, to use the data which Marden-Kane collects on its behalf in accordance with generally accepted privacy standards for both offline and online data, which includes an “opt-out” method for individuals who have provided personally identifiable information. Ultimately, however, Marden-Kane is not responsible for data collected on behalf of its clients when such data is in its client’s possession.

Information Collection and Use

Visitors to our web sites and the Promotion web sites built on behalf of our clients have the option of giving us contact information and other personally identifiable information, such as their name, mailing address, phone number and email address. This information is used by us to enter the visitor in a Promotion, provide information, assess the needs of a business to determine suitable products, and select and contact potential winners and other site visitors via phone, fax, email and regular mail.

When we receive, collect and process consumers’ personally identifiable information on behalf of our clients when we administer their promotions, we may also require sensitive information, such as social security number or date of birth. Consumers provide this information in a variety of methods, depending on the particular promotion. We only use this personally identifiable information to operate the sweepstakes or other promotion for our client, in order to select winners, award other prizes or bonuses or for the other purposes of the promotion. We do not use the information for any other purpose. We maintain the information only for so long as necessary to verify and conduct the promotion and to provide redundancy for our clients. We do not provide this information to any entity other than our client and others involved in the operation of the promotion. Our clients’ privacy policies govern the use of these data and they remain their property. Any exceptions to these procedures will be announced in the promotion for which the change is made.

Marden-Kane also processes personally identifiable information it receives directly from its’ clients. In these cases, Marden-Kane has no direct relationship with the 3rd party individuals whose personal data it processes. An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to Marden-Kane’s client (the data controller). If the client requests Marden-Kane to remove the data, we will respond to their request within 30 days.

It is the policy of this organization to retain client data, including personal data necessary for the selection, notification and awarding of prizes in promotions and any tax forms that are legally required to be completed for awarding those prizes, for only as long as legally required or as requested by the client, whichever is longer. No personal data is collected other than that required to select, notify and award a prize winner per applicable law. All physical documents are shredded and disposed of by a secure data disposal service. All electronic data is deleted and removed from all electronic devices including backups on a monthly deletion schedule. All requests from clients for data to be retained longer than legally required or transferred to them or another vendor must be made in writing and in advance.

We also collect certain information, not personally identifiable, on our website and in connection with administration of promotions. Marden-Kane may collect information about your computer configuration such as your browser type, operating system, or ISP domain name. Marden-Kane may collect information about the site you last visited prior to the Promotion or about your activity during your visit to the Promotion site. Marden-Kane may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, YouTube, Google or Twitter. By using these services you allow Marden-Kane to access the available information from your third-party social network profile such as your name, age, gender, location, email address and list of friends. This information may be used by Marden-Kane to administer the technical and operational aspects of the site, and may include using your IP address to help diagnose problems with our server. Your IP address may also be used to gather broad demographic information for aggregate use. This enables us to safeguard the promotion and diagnose problems in the operation of a promotion.

Marden-Kane may also use cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A session cookie might be used to track a user through a multi-page registration process so they would not have to reenter information multiple times during the registration process. A persistent cookie remains on your hard drive for an extended period of time. For example, we may set a persistent cookie for a day to prevent a user from returning to a site and trying to enter a Sweepstakes more than once a day. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. Each browser has a function which enables the user to disable cookies if so desired, but in that case, the participant may not be able to participate fully in a promotion, and certain aspects of our site may be limited. We also 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, track users’ movements and to gather demographic information about the user base of both our client’s promotions and our website. We do not link this automatically-collected data to personally identifiable information.

In addition to our own methods of anonymous data collection, our clients may use other types of tracking technologies. Unless otherwise stated, the use of cookies and other tracking technologies by our clients for the purpose of administering a promotion is not covered by our privacy policy. We do not have access or control over these cookies.

Onward Transfers

We will only transfer your personal information to third parties as set forth herein. We shall ensure that any third party for which Personal Information may be disclosed subscribes to the Privacy Shield Principles or are subject to law providing the same level of privacy protection as is required by the Privacy Shield Principles and agree in writing to provide an adequate level of privacy protection.

We do not sell your personal information to third parties.

Please note that Marden-Kane is obliged to disclose personal information in response to lawful requests by public authorities.

If Marden-Kane is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

In cases of onward transfers of Privacy Shield data to third parties, Marden-Kane is potentially liable.

Access and Choices Regarding Your Data

Upon request you may view and have inaccuracies corrected in contact information or other personally identifiable information, by sending us an e-mail to expert@mardenkane.com with “Contact Correction” written in the subject line and the correct information written in the body of the email, or you may mail us your request to the address below. We will respond to your request to access within 30 days.

If you have provided us with contact information or other personally identifiable information and do not want to receive e-mail from Marden-Kane in the future or wish to delete such information, please let us know by sending an e-mail to expert@mardenkane.com with “Remove from List” written in the subject line, or you may mail us your request to the address below.

When you provide personal information to us through our website, we will retain your information as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

The security of your personal information and our Client’s information is important to us. When sensitive information (such as a social security number) is entered in our promotion and sweepstakes forms, we encrypt the transmission of that information.

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at expert@mardenkane.com.

Other Privacy Information

Our Site includes links to other Web sites and we may develop Web sites on behalf of our Clients whose privacy practices may differ from those of Marden-Kane. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Our Web site also includes Social Media Features such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Our Web site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at expert@mardenkane.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Behavioral Targeting / Re-Targeting

At times, we may partner with a third party ad network to manage our advertising on other third-party sites. The ad network partner we utilize may use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Changes to This Privacy Policy

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you through email or prominent notice on our site before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses. The changes will also be noted in revisions to this privacy policy.

Special Note about Children

We abide by the Children’s Online Privacy Protection Act (“COPPA”). We will not knowingly allow anyone under 13 to provide to us, or to any of our clients on their behalf, any personally identifiable information.

Your California Privacy Rights (As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

Contact Us

If you have any questions about this privacy policy, the practices of this site or our company, or your dealings with this website, you can contact:

Privacy Officer
Marden-Kane, Inc.
195 Froehlich Farm Blvd
Woodbury, New York 11797

Phone: 516.365.3999

We can be reached via e-mail at: expert@mardenkane.com.

Last revised on April 12, 2017.