PRIVACY POLICY

Last modified: December 22, 2020

Lumen Marketing & Communications, LLC (collectively “we” or “our”) value our customers and partners, their personal information, their privacy and their trust. This Privacy Policy (“Policy”) explains how we collect, use, and protect information gathered through our website. Specifically, this Policy applies to our collection, use, processing, storage, and transfer of information associated with our website, www.lumenmarketing.com (the “Site”) and any other information you provide or we obtain. If there is something you do not understand about our privacy practices, please feel free to email us at privacy@lumenmarketing.com.

Your use of the website and our services constitutes your consent to the terms of this Privacy Policy. If you disagree with any Privacy Policy terms, please discontinue use of our website and services immediately.

Throughout this Policy, we refer to the term “Personal Information.” “Personal Information is data which identifies, describes, is associated with, or could be linked to an individual, such as a name, physical address, email address, telephone number, driver’s license, SSN or government-issued identification number, credit card number, date of birth, usernames, passwords, or the like. Data may be gathered through our website, as well as any related services, sales, marketing, or events.

Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, some of our customers are businesses, companies, institutions, or other entities rather than individuals. We do not consider business Information, such as title, employer’s name, work email, work phone number, work address, and other similar business information, to be Personal Information.

Information We Collect

Information You Provide

When you contact us through our Site, engage in activity on the Site, or inquire about our services through our Site, we may collect certain personal information from you, such as your name, company name, email address, physical address, phone number, and other information you may provide to us via the Site. This information might be used to communicate with you or to process a transaction. We keep this information only for as long as is reasonably necessary for the purposes for which it was collected.

Other Information We Collect

In addition to collecting information directly from you as described in the previous section, we also automatically gather information when you browse or view our Site. This information may include Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, whether you are a first-time or a returning user, links you clicked on while in the Site, and your flow and navigation path through the Site. We use this information to make sure that the Site and its associated parts are functioning properly, that the Site is displayed properly for your equipment and software, and that we can provide you with information useful to you and your location.

There are “do not track” or similar browser choices available to Internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Site will not operate any differently when a “do not track” signal is received.

In some of our email messages, you will find a “click-through URL” linked to content on our Site. We track this click-through data to help us determine interest in particular topics and to measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click on such links.

Cookies and Other Tracking Technologies

We use technologies such as “cookies” so we can remember certain information about you, remember your preferences, and recognize you when you return to the Site. Cookies help us understand how users use and navigate the Site. They enable us to compile aggregate data about Site traffic and Site interaction so we can improve our Site and enhance your user experience. A cookie is a text file that is stored on your device. Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all the features of our Site.

We also use log files, web beacons and pixel tags when you visit our Site. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information in our legitimate interest in administering the Site, preventing fraud, tracking website navigation in the aggregate, and gathering broad demographic information for aggregate use. Web beacons, also known as clear GIFs, are often used in combination with cookies. Often transparent, these images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Site is used. They are not used to access Personal Information. Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

We also may use device data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Site. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

We also may use location data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Site. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Website Analytics

We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

We also reserve the right to use any other analytics services, including analytics that connect to our email marketing, CRM systems, and forms of identification for those who access our website. These analytics services are used for improvement of our services and for marketing purposes. If at any time you wish to opt out of such analytics, you must avoid access or use of our website and contact us directly. If you are requesting deletion of such information pertaining to you, you can contact our webmaster identified below.

Use of Personal Information

We may use your Personal Information to further our legitimate business interests, such as to transact business, to provide information about our companies and our products and services, and to communicate with you. As described above, we may use Personal Information to send you requested information, to personalize content for you, to compile, analyze, and better understand user data, demographics and behavior, to post testimonials, to respond to legal requests, to send marketing and promotional communications to you, to deliver targeted advertising to you, and to detect, investigate, and prevent activities that may violate our policies or be illegal. We will only send marketing-related text messages with your express consent.

We also use the information automatically collected about you during your use of the Site, as described above, to improve the effectiveness of our website, operations, mobile experience, and/or marketing efforts, to prevent against fraud and theft, and otherwise to protect our Site’s visitors and our business.

Our employees and agents may view your Personal Information to perform their jobs and service your needs and the Site operations. This will help our employees and our system to facilitate account creation to send administrative information to you, and to enforce our terms and conditions. Our employees and agents will have access to your Personal Information on a need-to-know basis, and they will have a contractual obligation to protect the privacy of that information.

Sharing Your Personal Information

We do not sell any information we collect from you. We will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under circumstances described in this Policy.

We may provide your Personal Information, as outlined above, to our partners to assist us in operating the Site and transacting business and communicating with you. When we do so, we will exercise reasonable care to ensure that such partners are prohibited from using that information for any other reason and that such information is maintained securely.

We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Service, this Privacy Policy, or to otherwise protect our operations, legal rights, clients or users.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; to enforce the provisions of the Terms and Conditions of use of the website; to detect, prevent, or otherwise address fraud, security or technical issues; or to otherwise protect the rights, property or safety of us or others.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, transaction, or acquisition of all or a part of our business. If another company acquires ownership equity or the owner’s assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.

Site Not Directed to Children Under 18

Our Site is not directed to children under age 18 and we do not knowingly collect Personal Information from children under the age of 18. Children under 18 should not provide their Personal Information to us through our Site, to customer service, or in writing. If we learn that Personal Information belonging to anyone under the age of 18 is stored on the Site, we will immediately delete such information and refrain from using it for any purpose.

California Privacy Rights

If you are a California resident, you may have certain rights with respect to your personal information including the following rights:

1) the right to know, by way of our Privacy Policy and any specific inquiries you direct to us, where personal information we have about you comes from, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;

2) the right to “opt-out” of our sale of your personal information to any third parties;

3) the right, with some exceptions, to have your personal information deleted from our possession or control; and

4) the right to receive equal service and pricing from us even if you exercise any of your privacy rights.

California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, or if you have any questions or concerns about your California privacy rights, our Privacy Policy, or our use of your Personal Information, please send an e‐mail to privacy@lumenmarketing.com or write to us at:

Attn: Privacy Administrator
Lumen Marketing & Communications
44 Cook Street, Suite 100, Denver, CO 80206

For all California residents, any such inquiries shall be responded to within forty-five (45) days and at no cost to you. We will use information you have provided to us in connection with your activity on the Site to verify your identity in connection with any inquiries related to your rights noted in this Section.

If you are a California resident under the age of 18, and a registered user of any Site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@lumenmarketing.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

If you have questions or concerns about these rights and how they relate to this Privacy Policy or the Site, please direct your inquiries to privacy@lumenmarketing.com or write to us at:

Attn: Privacy Administrator
Lumen Marketing & Communications
44 Cook Street, Suite 100, Denver, CO 80206

European Privacy Rights (GDPR)

If you are an EU resident, you are afforded certain rights regarding your personal information. For example, EU residents have the following rights:

1) The right to be informed about what happens with your Personal Data (information relating to an identified or identifiable natural person), including how it is collected from you, how it is used as well as the right to access that Personal Data, to modify it when it is incomplete or incorrect, and the right to withdraw consent for its use;

2) The right to access Personal Data held by organizations about an individual;

3) The right to rectification allowing individuals to correct inaccurate information or complete incomplete information;

4) The right to erasure (or the right to be forgotten) allowing, with some exceptions, an individual to have his or her Personal Data deleted upon request;

5) The right to restrict and withdraw consent for data processing;

6) The right to data portability allowing individuals to ask for the transfer of their Personal Data or to obtain and use their Personal Data for their own purposes;

7) The right to object, with some exceptions, to the processing of an individual’s Personal Data;

8) The right to prevent automated decision making or profiling and to require that those decisions be made by natural persons.

If you have questions or concerns about these rights and how they relate to this Privacy Policy or the Site, please direct your inquiries to privacy@lumenmarketing.com or write to us at:

Attn: Privacy Administrator
Lumen Marketing & Communications
44 Cook Street, Suite 100, Denver, CO 80206

Links to Other Websites

While you are using the Site, you may be linked or directed to other third-party websites that are beyond our control. These third-party websites may have privacy policies and terms of use which differ from ours. Please carefully review these policies. We are not responsible for any actions or policies of such third parties.

Data Movement

We may maintain your Personal Information on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We process data, including Personal Information, in the United States. We transfer your Personal Information to another organization or a country only with your consent or to perform a contract with you, and consistent with the practices described in this Privacy Policy.

Security Measures

We maintain a variety of industry-standard security measures, including physical, electronic and procedural safeguards. For instance, we use SSL encryption technology for all information you provide us. No system or Site can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Your Access and Consent to Use of Your Personal Information

If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, you can contact our Privacy Administrator.

If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, please contact our Privacy Administrator. In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.

If you agree to receive future marketing communications directly from a third party through our Site, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s privacy policy.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes and clarifications will take effect immediately upon their posting on the Site and we will change the “Last Modified” date above.

Questions and Contact Information

If you would like to access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply request more information, you may contact us at:

Attn: Privacy Administrator
Lumen Marketing & Communications
44 Cook Street, Suite 100, Denver, CO 80206