This policy applies to:
Some user information you provide to us directly, some user information is collected automatically when you use the Services, and some user information we receive from third parties, such as our third-party vendors and publicly-available sources such as public websites.
When you use the Services, we also collect or receive general information (“Usage Data”) about you, either from you or other sources, such as personal identifiers (for example, IP address and device identifiers), demographic information, information about your preferences, interests, search queries, and online activity (such as date and time of your access to the Services, referring URLs, and information about the usage of our Services). Usage Data may also contain Personal Data.
Information that you provide to us.
We collect User Data that you provide directly to us, including as follows:
Please remember that any content (e.g., comments, photographs, information and other materials) that you post directly on our Services, including our social media pages, is public and can be read, collected or used by others. Please be cautious when disclosing any Personal Data through public activities or submissions.
Data that is automatically collected.
When you use the Services, we collect certain User Data about you automatically, including as described below.
We collect log files and other usage information when you access, use and interact with the Services (even if you have not created an account or logged into your account on the Services), including IP address, date and time that you signed up for an account, language setting, browser type, operating system type, internet service provider, referring/exit pages, page you requested, user agent, date and time stamps, clickstream data, and information about your search and click activity.
We (and third parties with whom we partner) may also deliver a file known as a web beacon, pixel or pixel tag to you through our Services. “Web Beacons” are small, invisible graphic images that may be used on the Services interface or in emails relating to the Services to collect certain information and monitor user activity on the Services interface, such as to count visits, access Cookies, understand usage effectiveness and to determine if an email has been opened and acted upon. “Pixels” or “Pixel Tags,” also known as clear GIFs, beacons, spotlight, tags or web bugs, are a method for passing information from the user’s device to a third-party website (for example, information about a user's browsing behavior, what links they click on, and purchases they have made on the Services).
We (and third parties with whom we partner) may deliver Web Beacons or Pixel Tags to you through our Services. Web Beacons allow ad networks, marketing partners and other service providers that we use to provide anonymized, aggregated auditing, research and reporting for us, for advertisers and our other partners. Web Beacons also enable ad networks and other partners to track your behavior for their own analysis and use, and to serve targeted advertisements to you on the Services or when you visit other websites or platforms. These Web Beacons enable third-party companies to view, edit, or set their own cookies when you visit the Services, just as if you had visited a web page from their site.
“Geo-Location Data” may be collected with your consent or inferred as you use the Services. Such information may include the location of the device used to access the Services, and may be derived from GPS or WiFi use or calculated based on your IP address.
Polls, surveys and quizzes
Information received from third-party sources.
We may receive User Data about you from third-party sources, including as follows:
We may also receive certain data (on an individual and/or aggregated basis) collected by our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) through the use of Pixel Tags, e-tags, IP addresses, Local Shared Objects, Local Storage, and Browser cookies, which allows us to:
Group Nine also works with third parties to provide analytics information regarding your usage of our Services or to help us track the advertisements that are delivered to you to determine the effectiveness of advertising on our Services.We may also link this information to User Data.
One example of an analytics provider used by Group Nine is Google Analytics. For more information on how to opt out of the processing of your data by Google Analytics, please see this page.
Advertising and marketing
Certain third-party vendors and partners (including, but not limited to, advertisers, advertising agencies, ad networks, ad measurement providers, and other marketing and advertising service providers and partners) (“Advertisers”) may collect information about you on the Services in order to provide you with relevant advertising on the Services and on other websites, platforms and media channels, and to analyze the performance of advertising campaigns. These Advertisers may use tracking technologies such as Cookies, Web Beacons, and other similar technologies, and may collect many different kinds of data, such as your IP address, device ID, advertising ID, and precise location data where made available by your mobile device.
The specific Advertisers we work with are subject to change at any time. For a list of some of the applicable providers or for more details on opting out of tracking for certain advertising purposes, please see the section below entitled How you can change or control what is collected.
The Services may feature Nielsen proprietary measurement software. To learn more about the information that Nielsen may collect, or to opt out of collection of your information by Nielsen, please visit the Nielsen consumer opt out page located here.
We may also sell or transfer User Data to certain Advertisers who will use this data for their own purposes, including to serve ads that they believe are relevant to your interests. Some of these third parties may combine the User Data with their own data about you to form a more detailed picture. We may also share User Data with Advertisers for the purpose of allowing them or their vendors or clients to send you marketing communications related to your use of the Services, their services or programs featured and/or advertised on the Services (e.g., through ads or Promotions), or their products, services and/or programs generally.
Some of our Services may use Facebook and Instagram features and tools, including Pixel Tags, which send data regarding your use of the Services to Facebook and/or Instagram for the purpose of tracking your interaction with the Services and with our brand on Facebook and Instagram, and to create custom audiences on the Facebook and/or Instagram platforms. Facebook and Instagram link the data collected on our Services with your account on their platforms and we and/or our Advertisers may use that data to serve you with advertisements both on and off of Facebook and Instagram.
We may provide certain Advertisers with information regarding your interactions with our emails and newsletters, other interactions or actions you take on our Services (such as clicks and purchases), or as to whether your information matches certain information held by the Advertiser and/or their customers. Those Advertisers may combine this data with information they collect for their own marketing purposes and in turn, may provide this information to their customers for their customers’ marketing purposes.
In order to help us sell advertising on the Services and otherwise publicize Group Nine and its products and services, we may also share aggregated statistics that describe our online audience. Those statistics are often based on the information you provide when you subscribe, register, browse the Services, and make purchases, and describe, among other things, the demographics of our visitors.
We employ or utilize the services of third-party vendors, consultants and service providers who need access to your User Data (such as your name, address, email, or other identifiers) in order to enable them to perform services on our behalf or to provide us with additional information necessary to provide you one of our Services to you (“Service Providers”). We use Service Providers for a variety of services across our Services, such as email message deployment, email address validation, subscription fulfillment, research and insights, statistical analysis, cross-device user tracking and targeting, data and website hosting, marketing, advertising, and other data and transaction processing.
We also engage Service Providers for the purpose of processing payments for purchases of content, subscriptions and physical goods through our Services, to fulfill your orders for product purchases, to honor your request to be removed from promotional mailings, and to monitor, analyze and prevent fraudulent traffic or other suspicious activities on our Services or on other services. For our Voices platform, we may also provide your User Data to Service Providers in order to process payments for services if you are selected for a paid assignment under those platforms.
In addition to receiving your User Data from us, our Service Providers may also:
Third-party partners and websites
Please note that your interactions with these third-party services and any data or other information (including Personal Data) that you provide to such third parties is subject to the terms of the applicable third-party terms of service and privacy policies. We are not responsible for any such third-party terms or policies and you should review them carefully.
Social plug-ins and embeds
User profiles and submissions
Certain User Data from your profile such as your user name, display name, biographical information, or any comments or video or image content that you have uploaded to the Services may be displayed to other users to facilitate user interaction within the Service or address your request for Services. In some applications, information you share in your profile will be publicly available to other users.
Text message services
Payment card information
To use certain aspects of our Services, such as participating in our POPSUGAR Must Have It Service, we may require you to submit credit or debit card account information. By submitting your credit or debit card account information or other financial information through the Services, you expressly consent to the sharing of this information with third-party retailers, subscription and billing processors, and payment processors.
Certain areas of the site may use third-party payment processors to enable purchases. If you make a purchase via one of these third-party payment processors, the payment processor may store your credit or debit card account information and other financial information so you can use our Services in the future. We do not have access to your complete credit or debit card account information, social security number, or other financial information. We do not store or have direct control over or responsibility for your credit or debit card account information, social security number, or other financial information as transmitted to such third-party payment processors. We cannot guarantee that transmissions of your credit or debit card account information or other financial information, or other Personal Data will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers.
We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
When you submit a photo to Twinning, we post a composite image of your photo and your celebrity look-a-likes on a public URL for you to reference and share with your friends. When you submit a photo to Aura by POPSUGAR, we post an image of your photo with your aura reading results on a public URL. For both Twinning and Aura by POPSUGAR, while we only provide this unique URL to you, the URL is public and may be viewed by anyone who has the link. You can request removal of any unique URL created in connection with your photos through Twinning or Aura by POPSUGAR by contacting us at firstname.lastname@example.org.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your User Data may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
Enforcement of terms and policies
Protection of Group Nine and others
We may access, read, preserve, and disclose any User Data where we reasonably believe a disclosure is necessary to comply with law or court order; or protect the rights, property, or safety of Group Nine, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With your consent
We may share your User Data in other circumstances with your consent, for example when you have chosen to link an account with our Services with a social media network like Facebook or Google.
Changing your account settings
You may add, update or delete information through your user account settings, which limits the ability of other users to see the information in your user profile. The information you can view, update, or delete may be different depending on which area of the Services you are using and may also change as the Services change.
If you have any trouble accessing, correcting or deleting any of your information, please contact us at email@example.com and we will respond to your request within a reasonable timeframe.
You can usually instruct your browser by changing its settings to stop accepting Cookies or to prompt you before accepting a Cookie from our websites that you visit. If you choose to disable Cookies, you may not be able to use all portions of the Services or all functionality of the Services.
Opting out of tracking
The specific Advertisers we work with are subject to change at any time. For a list of some of the applicable providers or for more details on adjusting your cookie settings, including opting out of tracking for advertising purposes, please click on the Cookie Settings button in the footer of every page on the Services. Please note that if you intend to opt out of tracking for advertising purposes, you will need to adjust your Cookie Settings separately for each brand.
California residents can opt out of the sale of their personal information, as “sale” is defined in the California Consumer Privacy Act (CCPA) by filling out the form here, or by clicking on the “Do Not Sell My Personal Information” link in the footer of every page on the Services.
Some of the trusted third parties collecting data on our Services via tracking technologies may also be members of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA). For an explanation of that technology and how to control the tracking from those providers that participate in the DAA program, the consumer awareness section of the DAA’s website (www.aboutads.info/consumers) provides a good overview. You may also use the DAA’s opt-out option available at http://www.aboutads.info/choices/. For more information about targeted advertising and the opt-out procedures of NAI members, see http://www.networkadvertising.org/choices/.
Please note that cookie-based opt-outs are not effective on mobile applications. Users may opt out of certain advertisements on mobile applications or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS device, click here, and on your Android device, click here.
You may also download and set your preferences on the DAA’s App Choices mobile application(s) available in Google Play or the Apple App stores.
More information about opting out on mobile devices is available here.
The Services may feature Nielsen proprietary measurement software. To learn more about the information that Nielsen may collect, or to opt out of collection of your information by Nielsen, please visit the Nielsen consumer opt out page located here.
Precise location data
You may opt out of having your precise location data collected by us at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).
Newsletter and email subscriptions
Deactivating your account
You can always choose not to disclose information to us or delete information, but keep in mind some information may be needed to register with us or to take advantage of some of our special features. You may request deactivation of your account by contacting us at firstname.lastname@example.org.
De-linking your account
In order to de-link your Group Nine account(s) from an account on another service such as a social media account, you must adjust your account settings with the third-party application. For example, if you want to de-link your Facebook account with Group Nine, you must de-link your accounts in both your Group Nine account settings and in your Facebook application settings.
You may adjust the “Settings” on your mobile device settings (or within the “profile” tab of certain applications) to disable push notifications for any of our mobile applications for which you would like to stop receiving such notifications. You may adjust the “Notification” settings usually found in your browser “Preferences” or “Settings” to block or remove certain browser-based push notifications.
If you no longer wish to receive text messages from our POPSUGAR Must Have It Service, you can reply “STOP” to any text message sent by us through such Service or text “STOP” to 441-76. For our POPSUGAR Must Have It Service, if you have a POPSUGAR Must Have It account linked to the phone number you provided for the POPSUGAR Must Have It Service, you can also visit the “Account Settings” page in your POPSUGAR Must Have It account and change the POPSUGAR Must Have It Phone Number settings from “on” to “off.”
Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website.
In accordance with the California Online Privacy Protection Act (see California Civil Code Sections 1798.83-1798.84), California residents are entitled to ask us for a notice identifying the categories of certain Personal Data that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and wish to make such a request, please submit your request in writing to email@example.com.
If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at firstname.lastname@example.org.
The information below applies to users located in the United Kingdom (“UK”) or the European Economic Area (“EEA”) only.
Legal bases of processing Personal Data
Legal rights of UK and EEA users
How to exercise your rights.
You may exercise any of the rights described in this section. If you would like further information in relation to these or would like to exercise any of them, please contact us using the contact details in the section below entitled How to contact us. Please note that we may ask you to verify your identity before taking further action on your request.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain User Data may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request.
You have the following rights:
Right of access
You have a right of access to any Personal Data we hold about you. You may access and update some of your Personal Data through your user account settings on the applicable Services. You may add, update or delete information, which limits the ability of other users to see the information in your user profile. You can ask us for a copy of your Personal Data; confirmation whether your user information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the EEA or UK, as applicable.
In order to de-link your Group Nine account from your account on Facebook or Google, you must adjust your account settings with the third-party application. For example, if you want to de-link your Facebook account with Group Nine, you must de-link your accounts in your Facebook application settings.
Right to update your information
You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you that we hold.
You have a right to ask us to provide your Personal Data to a third-party provider of services. This right only applies where we use your Personal Data on the basis of your consent or performance of a contract; and where our use of your Personal Data is carried out by automated means.
Data retention and erasure
You have a right to ask us to delete any Personal Data which we are holding about you in certain specific circumstances. If you no longer want us to use your Personal Data to provide Services to you, you can request that we erase your Personal Data and close your user account(s).
We will pass your request onto other recipients of your Personal Data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in the section below entitled How to contact us.
Please note that if you request the erasure of your Personal Data:
Withdrawing consent and restriction of processing
(a) Withdrawing consent.
Where you have provided your consent to the processing of your Personal Data by Group Nine, you may withdraw your consent at any time. Please see the section above entitled How you can change or control what is collected for more information.
Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent prior to your withdrawal of consent.
(b) Restriction of processing.
Additionally, you have the right to limit the ways in which we use your user information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting using the contact details in the section below entitled How to contact us.
We will pass your request onto other recipients of your Personal Data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are by contacting us using the contact details in the section below entitled How to contact us.
Objection to processing
You are also entitled to require that we not process your Personal Data for certain specific purposes where such processing is based on legitimate interest. If you object to such processing, we will no longer process your user information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Right to stop marketing
Where your user information is processed for direct marketing purposes, you may, at any time, submit a request asking us to cease processing your data for these direct marketing purposes by contacting us using the contact details in the section below entitled How to contact us.
In accordance with Article 77 of the General Data Protection Regulation, you have the right to lodge complaints about the data processing activities carried out to the UK Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
We use commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through our Services. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed by unauthorized persons or hardware or software failure.
The main risk of our processing of your User Data is if it is lost, stolen or misused. This could lead to your User Data being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private. For this reason, we take reasonable precautions to safeguard the confidentiality of your user information, including through use of appropriate organizational and technical measures.
In the course of provision of your User Data to us, your User Data may be transferred over the internet. Although we make reasonable efforts to protect the User Data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your User Data transmitted to our website and that any such transmission is at your own risk. Once we have received your User Data, we will use strict procedures and security features designed to prevent unauthorized access to it.
Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you that you create a strong, unique password that you do not use on other sites and that you do not share your password with anyone. You are ultimately responsible for the security of your email address and password.
We especially care about the privacy of young children. Most of our Services are not directed to children under the age of 16 and except as set forth below, we do not knowingly collect Personal Data from children under the age of 16 on such Services. If we learn that we have collected Personal Data from a user under 16 years of age on such Services, we will promptly delete any Personal Data that the individual has provided to us.
A few of our Services are clearly identified as being marketed directly to children under the age of 16 (such as our Dodo Kids channel on YouTube). In connection with such child-directed Services, we do not knowingly collect any Personal Data from users under the age of 16 without complying with applicable legal requirements and making appropriate disclosures.
Your User Data may be used, stored, accessed, transferred to and maintained on devices, servers located outside the territory in which you reside, including to servers and staff located in the United States. Data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If we provide any User Data about you to any other third parties, we will require the recipient protects your User Data in accordance with applicable law.
To the extent that Group Nine is deemed to transfer any Personal Data of UK or EEA users outside of the UK or EEA, we rely separately, alternatively, and independently on certain transfer mechanisms to transfer such Personal Data as described below. We will provide further information on the means to ensure an adequate level of data protection for your Personal Data upon your request, which can be directed to us using the contact details in the section below entitled How to contact us.
Standard contractual clauses
The European Commission has adopted standard contractual clauses (also known as model clauses), which provide safeguards for user information that is transferred outside of the EEA or UK. We often use these standard contractual clauses when transferring User Data outside of the UK or EEA, as applicable.
In some cases, we may transfer your User Data to certain third-party service providers and partners of Group Nine based on an adequacy decision of the UK or European Commission confirming an adequate level of data protection in the country of the receiving party.
The time period for which we keep User Data varies according to the information’s use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
Group Nine Media, Inc.
568 Broadway, 10th Floor
New York, NY 10012