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 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 of overall demographic data (this data is not personal identifying data). 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. If you wish to “opt-out” of a promotion that is currently available, please complete and submit the online form at https://promotions.mardenkane.com/ForgetMe/. Any “opt-out” requests that are made after the promotion has ended should be directed to the 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.

Use of Cookies

Marden-Kane may also use cookies, and you must provide consent for the use of cookies on any Marden-Kane hosted site which uses them. 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

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). We shall ensure that any third party for which Personal Information may be disclosed agree in writing to handle the data under the same level of protection as set forth in this policy.

We do not sell your personal information to third parties.

In certain situations, Marden-Kane may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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.

Marden-Kane’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Marden-Kane remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Marden-Kane proves that it is not responsible for the event giving rise to the damage.

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 completing the form at https://promotions.mardenkane.com/ForgetMe/ or 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.

EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, correct or amend their data should direct their query to expert@mardenkane.com, or if they wish to delete their data, should complete the form at https://promotions.mardenkane.com/ForgetMe/. If requested to remove data, we will respond within a reasonable timeframe.

Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

If we were ever to share data in the future, we will provide an individual opt-out or opt-in choice before we share data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to expert@mardenkane.com.

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.

Privacy Shield Frameworks

Marden-Kane, Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US 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 transferred to the United States pursuant to Privacy Shield. Marden-Kane has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under 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/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Marden-Kane is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

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 transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Marden-Kane at:

expert@mardenkane.com

Marden-Kane, Inc. has further committed to refer unresolved privacy complaints under the 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 www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

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:

Data Protection Officer
Marden-Kane, Inc.
575 Underhill Blvd. Stuite 222
Syosset, NY 11791

Phone: 516.365.3999

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

Last revised on May 18, 2018.
Revisions include:
Cookie clarification and notice of consent added.
Addition of a link to our “opt-out request” form
Behavior targeting/re-targeting removed as it is no longer applicable
DPO listed as contact person instead of Privacy Officer

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.