EU-US Privacy Shield Policy
Infinite Media Concepts LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
Infinite Media recognizes that the EU has established certain protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about corporate customers, clients, suppliers, and business partners received in the US, Infinite Media has elected to self-certify to the EU-US Privacy Shield Framework, collectively administered by the US Department of Commerce (collectively, “Privacy Shield”).
This is consistent with our commitment to comply with the principles of the EU General Data Protection Regulation (GDPR) regarding the rights of individuals regarding their personal data, as well as aiding the goal of standardized data protection practices throughout the EU.
Infinite Media has an affirmative commitment to comply with the Privacy Shield Framework, and it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
Personal Data Collection & Use, Including Data Transfers Received from Third Parties
Before we use your EU Personal Data for a purpose that is materially different than the purposes for which we collected it, or for other purposes for which you provided it to our contractual third parties, or that you later authorized, we will provide you with the opportunity to opt out. Infinite Media maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.
Data Transfers to Third Parties
We do transfer EU Personal Data to certain third-party agents or service providers with whom we have entered written agreements and which agreements addresses data privacy and security policies and procedures that requires all contractual parties to ensure that your EU Personal Data is protected with the same level of protection the Privacy Shield requires. We also may transfer your EU Personal Data to one of our affiliated entities, when we have taken steps to ensure that your EU Personal Data is protected with the same level of protection the Privacy Shield requires.
Infinite Media will take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; Require the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and Provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.
Right to Access Personal Data
You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Your Data Choices and Opt-Out Rights
- Opting Out of Infinite Media’s Database. Send an email to us at [email protected] to opt out of the Infinite Media database. If you do so, please include the following information in your email: (a) first and last name, and (b) current address. We also recommend that you provide us with other addresses you have lived at in the past five years, which may help us to opt you out even if we have not yet acquired your current address information. If you decide to opt out in this way, we will stop using data in Infinite Media proprietary database to help our customers send or tailor ads and content to you, including through email, direct mail or online display marketing. (It usually takes us between 30 to 60 days to process this opt out through all of our databases.) Doing so will not opt you out of our customers’ or our partners’ databases, only data in Infinite Media’s own database – so other companies that we work with may still send ads, offers and content to you.
- Opting Out of Online Targeting. If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. Opting out through the above methods will cause one or more opt-out cookies to be set on your browser or device, to indicate that you have opted out. Opting out in this way won’t prevent you from seeing ads: but it will in many cases lead the companies listed to stop customizing ads based on inferences they have made about you or your interests. Note that opt-outs are browser-specific, so opting out on one browser will not affect a second browser or device that you use. For the same reason, if you buy a new device, change browsers or clear all cookies, you’ll need to perform this opt-out task again.
- Unsubscribing from Our Emails. In addition, when we send an email to you (whether on our behalf or on behalf of a client), we will provide a way for you to opt out of receiving emails from us in the future. Usually, this appears as an “unsubscribe” or “opt out” link in the footer of the email.
FTC Compliance & Accountability
For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.
To review Infinite Media’s entry on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.
Privacy Shield Program Assistance: (Select Dispute Resolution and Assistance for Complaint Submission Form)
Right To Invoke Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Infinite Media and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority (DPA) and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
Disclosures for National Security or Law Enforcement – Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Liability in Cases of Onward Transfer of Data
In cases of onward transfer to third parties of EU Personal Data that is received pursuant to the EU-US Privacy Shield, Infinite Media may be potentially liable in certain circumstances.
Infinite Media maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
In the event Infinite Media should leave the Privacy Shield Framework, it certifies its commitment to apply the Principles to information received under the Privacy Shield Framework if it chooses to keep such data or provide “adequate” protection for the information by another authorized means.
Questions or Complaints
In compliance with the Privacy Shield Principles, Infinite Media Concepts LLC commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Infinite Media at: [email protected].
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. If you are unsatisfied with the resolution of your complaint, please contact the independent recourse mechanism listed below:
NON-HR RECOURSE MECHANISM:
If an individual submits a complaint to a data protection authority (DPA) in the EU, the Department of Commerce has committed to receive, review and undertake best efforts to facilitate resolution of the complaint and to respond to the DPA within 90 days. Infinite Media will respond promptly to inquiries and requests by the Department of Commerce for information relating to the Privacy Shield Framework.
Infinite Media will make public any relevant Privacy Shield-related sections of any compliance or assessment report submitted to the FTC if becomes subject to an FTC or court order based on non-compliance.
Infinite Media is committed to cooperating with EU data protection authorities and will comply with the advice given by such authorities with regard to data transferred from the EU.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.
If you have any questions about this Policy or would like to request access to your EU Personal Data, please contact as follows:
Email: [email protected]
Privacy & Data Security Officer, Infinite Media Concepts
190 East Post Road
White Plains, NY 10601
Effective Date 12/17/18Last Updated 12/12/19