Last Updated: November 24, 2020
GWM implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, ensures data is only transferred internationally with a lawful basis, only contracts with processors and sub-processors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.
Personal data (or personal information) comprises all information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household, such as a real name, postal address, e-mail address, telephone number, payment information, and account ID. When other information is directly associated with personal data, that information may also be considered personal data. Information that is aggregated, de-identified, or anonymized is not considered personal data. Publicly available information that is made available from federal, state, or local government records, also may not be personal information.
The collection of personal data is based on legitimate interest according to the above and for the performance of a contract to which you and GWM are the parties.
For the purposes of compliance with the California Consumer Privacy Act of 2018, GWM is a covered business with respect to information that is provided by you, directly or automatically, when you visit Our Website. GWM is not a covered business with respect to activities GWM undertakes on behalf of its Clients, in which it acts as a service provider on behalf of its clients. GWM encourages you to visit its Clients' websites, or contact its Clients directly, should you wish to learn more about their personal information practices, or to assert any rights under this law.
Collection of Personal Data and Other Information
By providing our technologies and services we may collect information about your device, its unique ID, operating system and browser as well as your IP address. The way you get in touch with us or our technologies and services determines the scope of how we collect and process personally identifiable information. Data as a general term may include all kinds of information such as your name, your address or information on your device (e.g. your operating system or browser).
a. When visiting our website www.globalwidemedia.com or when you contact us
This section provides information on how and which data we may collect from visitors to Our Website and those individuals who contact us. This information may be provided by your directly, or may be collected automatically from your device.
Visiting and surfing on our website is possible without cookies. Most browsers accept cookies automatically. You may delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. You may also alter the security settings of your web browser to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites only, or to be notified before receiving cookies. Please note, however, that these settings may have negative effects on the usability and user guidance of websites and other online services. If you are a registered publisher, certain parts of Our Website may only be used fully if your browser allows cookies.
You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
Cookies used on our website are listed below.
Cookie name Purpose _ga
Analytic cookies by Google Analytics, please find more information:
Wp32058 Third party cookie placed by Act-on for marketing and aggregation purposes. For more information about Act-On's cookies, please visit https://university.act-on.com/User_Guides/Inbound_Marketing/The_Website_Prospector/Beacon_Tracker_Overview
ii. Third Party Cookies
Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party's website for more information about cookie management and how to "opt-out" of receiving cookies from them.
If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices.
b. When you contact us
Regardless of how you contact us, we may collect personal data, such as your contact and identification information, including name, title, email address, postal address, and phone number. We may also collect any other personal data you provide to us in your communications with us. We may receive this information directly from you, or automatically; for example, when you call us, we may receive your telephone number.
c. When you are our Client or becoming one
You need to register in our Network to obtain access to our platform and services as a publisher. If you enter into a contractual relationship with us and/or register in our Network, we record all data, including personal data, which has been provided by you such as your name, address, telephone number, email address. You can see from our online registration form which personal data in detail we record. We do not record any further personal data other than voluntarily provided by you (e.g. in response to a request for information).
In the event your application to become a Publisher of GWM is not successful, your information will be stored by GWM for archiving purposes and will not be shared with any third parties unless it is in response to a demand by law enforcement authorities in connection with a criminal investigation, or by civil or administrative authorities in connection with a pending civil case or administrative investigation.
By registering with our Network you give your consent that we may contact you via telephone, via mail and email in order to provide you with information on GWM offers. You may withdraw your consent at any time by contacting us using the information in the Contact section below.
d. When using our services via websites and online services of our Clients
Our tracking cookies are listed below.
Cookie name Purpose ho_mob This is a hash of the user's device/connection information. This hash is used for offer targeting. enc_aff_session_* This is an offer specific cookie. It includes the user's transaction_id and IP address for tracking conversions. The * denotes the offer ID. There will be a different version of this cookie for each offer that is clicked Aff_conversions This cookie stores the offer_id of all offers that the user has converted for GWM
e. When you apply for a job with us
If you apply for a job with us, we will collect additional information in connection with your application. This may include: Name and contact information; Username and password; Work authorization status; Resume, CV, cover letter, work experience, and education information; Skills; Professional and work-related licenses, permits, and certifications held; Reference-related information; and Any other information that is publicly available or that you elect to provide to us (e.g., current salary, expected salary).
Processing and use of personal data
Visitors to our websites and those who contact us
We use personal data provided by our clients only for administrating and providing our services, for responding to clients' inquiries and, where applicable, executing the contract between a client and GWM, including payment processing. We store personal and any other kind of data strictly in compliance with applicable data protection and privacy legislation and our contractual duties, and will prevent unauthorized access to data to the best of our abilities.
We may transmit your data to our subcontracted service providers, but only if we contractually assigned these providers to process data on our behalf and, both ourselves and the subcontracted service providers comply with all requirements of applicable data processing regulations pursuant to laws on data protection.
Users of Clients' websites
We use your data to provide our marketing services on behalf of our Clients. GWM encourages you to visit its Clients' websites, or contact its Clients directly, should you wish to learn more about their personal data practices.
Information from job applicants may be collected from you directly, from your references, from a recruiter, from your prior employers, and from your places of education. We will only use this information to evaluate your candidacy, including by processing your application, assessing your qualifications, corresponding with you, and complying with legal obligations.
Disclosure of Your Personal Data
GWM does not sell your personal data, and will not sell your personal data. GWM may share some or all of your personal data:
GWM takes all reasonable technical, physical, and organizational security measures required to protect your personal data from loss, unauthorized disclosure or other forms of misuse. Data is stored in a safe environment that is not open to public access. Our staff has been trained in privacy matters and in dealing with data and information, which they gain access to in a responsible manner. We encourage you to similarly be cognizant of safeguarding your personal information.
Your Choices and Rights Relating to Your Personal Data
You may have a right to access, delete, or rectify your personal information. If you are registered as a Publisher, you may access your publisher account and rectify some of your data yourself. In all other cases you may make a request by contacting us using the information provided in the Contact Us section below. Exceptions may apply, including based on whether your request is permitted or required by law.
Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information; (iii) the right to object to unlawful data processing; (iv) the right to erasure of personal information about you; (v) the right to demand that we restrict processing of your personal information if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (vi) the right to data portability of personal information that you provided us in a structured, commonly used, and machine-readable format; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.
We may require that you provide appropriate identification to fulfill your request. Any such identifying information will be used only for this purpose.
International Transfer and Storage of Information
If you are a California resident, the California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA), may afford you the right, following a verifiable request, to:
(1) access—twice in a 12-month period, free of charge—the categories and specific pieces of personal information GWM has collected about the you, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom GWM shares personal information, for the 12-month period prior to the request; and
(2) delete personal information under certain circumstances.
GWM does not discriminate against you on the basis of your exercising any rights afforded by the CCPA, which is further in accordance with California residents' rights under that title.
Following any request, we will verify your identity using data points you have previously provided to us. Please have this information available so that we can verify your request. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.
Further, in accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to email@example.com. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov.
California Do-Not-Track disclosure requirements
GWM is committed to providing you with meaningful choices about the information we collect, and that is why we provide the below NAI Out-out link. However, we do not recognize or respond to browser initiated Do Not Track signals.
We do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you should not provide us with your personal information. If you are a parent or guardian and discover that your child under the age of 16 has provided personal information, then you may alert us as set forth in the "Contact Us" section below and request that we delete that child’s personal information from our systems.
Retention of Personal Information
We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. If you would like further information regarding the periods for which your personal information will be retained, please contact us as set forth in the "Contact Us" section below.
Links to Other Sites
This website may provide links to other websites. GWM does not endorse these websites, and is not responsible for the content of third-party websites. Nor GWM have any control over information you may choose to provide to those websites.
GWM may serve interest-based messages (banners or links) on behalf of organizations across the Internet. GWM may receive anonymous information about your interests and use this information to display messages for issues that may be of interest to you. Please note that these messages do not reflect the views or opinions of GWM.
The Network Advertising Initiative (NAI) works with providers like GWM to promote responsible online communication practices. To help you understand how this messaging works, the NAI has developed an informative site to help you safeguard your online privacy and provide a way for you to opt-out of interest-based messaging. To learn more visit the NAI.http://optout.networkadvertising.org/?c=1#!%2F
Your interests are associated with a cookie or similar technology that associates devices or browsers. By selecting the below, you will be able to control whether and how Company serves messages to you by using the cookie. Remember, if you opt-out you will continue to receive messages, but they will not be as relevant to you.
If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.