Searchgage Media LLC is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

Our full details are:

Legal entity: Searchgage Media LLC
Legal entity postal address: 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801, United States
Data Protection Officer (DPO): Tino Umo
DPO postal address: Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA
Email address: privacy[at]searchgage.com (replace [at] with @ when making contact)

2. Data Collected, Usage, and Grounds

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data - Includes any communication that you send to us, whether that be through the contact form on our website, through email, text, social media messaging, social media posting, or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records, and to establish, pursue, or defend legal claims.
Customer Data - Includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data - Includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases, and to enable the publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.
Technical Data - Includes data about your use of our website and online services, such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings, and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you, and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business, to grow our business, and to decide on our marketing strategy.
Marketing Data - Includes data about your preferences in receiving marketing from us and our third parties, as well as your communication preferences. We process this data to enable you to partake in our promotions, such as competitions, prize draws, and free giveaways, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services, to develop them, to grow our business, and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you (including Facebook or Google adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us, with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered; however, if we do, we will notify you at that time.

We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this, please email us at privacy[at]searchgage.com (replace [at] with @ when making contact). In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision-making or any type of automated profiling.

3. How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties, such as analytics providers like Google based outside the UK and/or the EU, advertising networks like Facebook based outside the UK and/or the EU, and search information providers like Google based outside the UK and/or the EU, as well as providers of technical, payment, and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources, such as Companies House and the Electoral Register, based inside or outside the UK and/or the EU.

4. Marketing Communication

Our lawful grounds for processing your personal data to send you marketing communications are either your consent or our legitimate interests (namely, to grow our business).

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask us to stop sending you marketing messages at any time by emailing us at privacy[at]searchgage.com (Replace [at] with @ when making contact).

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. Disclosures Of Your Personal Data

We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors, and insurers.
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Where you are within the United Kingdom:

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom have approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of a UK regulator-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the UK, we may use specific contracts, codes of conduct, or certification mechanisms approved by the United Kingdom regulators that give personal data the same protection it has in the UK.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Where you are within the EEA:

We are subject to the provisions of the EU General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of an EU-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the EEA, we may use specific contracts, codes of conduct, or certification mechanisms approved by EU regulators that give personal data the same protection it has in the EEA.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature, and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and whether these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes; in which case, we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data, and (where the lawful ground of processing is consent) to withdraw consent.

If you are within the UK, you can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at privacy[at]searchgage.com (Replace [at] with @ when making contact).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you.

If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you have a complaint so that we can try to resolve it for you.

If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We would be grateful if you would contact us first if you have a complaint so that we can try to resolve it for you.

10. Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly. For more information about the cookies we use, please view our Cookie Policy.

California Privacy Protection Act Notice

This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS intended to apply solely to visitors, users, and persons who are residents in the State of California ("consumers" or "you").

This notice is an addendum for information contained in the existing Privacy Policy of the Company and its affiliates (collectively, "we," "us," or "our").

We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect -

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information").

We have collected the following Statutory Defined Categories of personal information from consumers within the last twelve (12) months:

Category: "Identifiers" - which may include: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

Category: "Customer Records" -which may include: A name, signature, address, telephone number, education level, employment, driver license status and medical information Some personal information included in this category may overlap with other categories.

Category: "Protected Classification Characteristics"- which may include: Age, marital status, gender, and Veteran or military status.

Category: "Internet or Other Similar Network Activity"- which may include: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Category: "Geolocation Data" - which may include location of ISP.

Category: "Professional or Employment-Related Information"- which may include employment status, ie. Employed, Self-Employed or Retired Status.

The above categories of personal information are obtained from the following categories of sources:

Directly from you. For example, from your interaction on this platform and the information you provide on any forms this platform which you submit. In some instances we may also automatically collect certain information from you through the technology on the platform.
Information you provide in connection with a product/service offered by our affiliates, partners or vendors.
Information you provide the platform for communication permissions and consents.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing marketing or technology services to them.
Directly or indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
From third-parties that interact with us in connection with the platform function or services we perform. For example, verification services used for state and federal permission and consent records.
Information you provide us through telephone and websites, customer service correspondence, and general feedback.
In addition, we may receive information about you from other online or offline sources, including service providers from whom we validate consumer self reported information, and verify information we already have about you.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To process an inquiry or request you provide. For example, if you provide us with your information to share with businesses who will contact you regarding a product or service you expressed interest in.
To provide you with personalized email, SMS or tele communications concerning products or services, information or news, that you may be of interest to you through targeted offers and ads (with proper consents, where required by law).
To carry out our obligations and enforce our rights arising from any contracts entered into between us and any affiliates, client network, and/or vendors.
To improve our platform and the services offered.
For testing, research, analysis and technological/product development.
To help maintain and protect the rights, safety, security, and integrity of our platforms, products and services, databases and other technology assets.
To respond to any law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for any other purpose than described herein without first providing you notice.

Sharing Personal Information

We may share your personal information with a third party for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services outlined in the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information (as identified above) for a business purpose:

Category: Identifiers
Category: Customer Records
Category: Protected classification characteristics
Category: Internet or other similar network activity
Category: Professional or employment related information

We share the above following categories of personal information for a business purpose to the following third parties:

Our affiliates.
Service providers.
Data aggregators.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services you have expressed interest in.

Your Rights and Choices

Right to Opt-Out of the Sale of Personal Information-

You have the right to opt-out of any sale of your Personal Information by us. If you are requesting a product or service, this is an exemption from this right, and we will process your request. However, you have the right to cease all further sale of your Personal Information.

Per California CCPA Section 1798.140(t): A business does not sell personal information when: A consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title.

In the preceding twelve (12) months, we have shared your information with providers of the services or products you have requested. We have also shared your information with third parties as described above.

To Opt-Out of the sale of Personal Information, please see Section: Exercise Your Rights below.

Right to Know About Personal Information-

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. Personal Information does not include: (i) Publicly available information from government records; (ii) De-identified or aggregated consumer information; (iii) Information excluded from the CCPAs scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); (iv) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), or the Drivers Privacy Protection Act of 1994 (DPPA).

You may submit a verifiable consumer request to obtain the specific Personal Information we have collected about you at the link or email address provided in Section: Exercising Your Rights, below.

Once we receive and confirm your verifiable consumer request, we will provide:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, two separate lists disclosing the following will be provided:
- Information you provided that was shared with third parties for the purposes set forth above and resulted in payment to us which will identify the personal information categories that the third party purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Delete Personal Information

You have the right to request that we correct and/or delete any of your personal information you provided to this platform and retained, subject to certain exceptions. Upon receipt and confirmation of your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may retain your information despite your deletion request if retaining the information is necessary for us or our vendors/ service providers to perform any of the following:

Process your request for which you provided your personal information
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality of this platform/service.
Internal uses that are reasonably aligned with consumer expectations based on your engagement with the platform/services..
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercise Your Rights

To exercise your rights as described above, please submit an email to: privacy[at]searchgage.com (replace [at] with @ when making contact).

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information or on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person (or authorized agent) who provided personal information on the platform.
Describe your request with satisfactory detail that allows us to accurately understand, evaluate, and provide a response.

The above details are important. We will be unable to process/respond to your request or provide you with personal information if we cannot conclusively verify your identity or any authority to make the request and/or confirm the personal information relates to you.

We will only use the personal information provided in a verifiable consumer request to actually verify the requestor's identity or authority in order to process such request.

Response Timing and Format

We will respond to a verifiable consumer request within 45 days of its receipt as required. If more time is required (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver a written response by mail or electronically, at your request. The information provided will cover a 12-month period preceding the verifiable consumer request's receipt. The response we provide may also explain the reasons we cannot process a request, if applicable. For requests made, we will select a format to provide your personal information that is readily useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny these services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of services. Please note: We do not charge consumers for use of these services.
Provide you a different level or quality of services.

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Company

Searchgage Media, LLC
1309 Coffeen Avenue STE 1200
Sheridan, WY 82801
United States

US: +1 (929) 502-2223

UK: Click Here For Contact

UK ICO No: ZA912827

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1. Introduction