Privacy Policy

ListenFirst

Last Updated and Effective as of: March 27, 2019 Welcome to Listen First Media located at https://www.listenfirstmedia.com/ (the “Website”).  This Website is owned by Listen First Media LLC (“Company”, “we”, “our” or “us”). We have created this Privacy Policy in order to demonstrate our commitment to your privacy. The Privacy Policy below discloses our practices regarding information collection and usage for the Website. This Privacy Policy does not apply to any other websites, apps or services provided by us, our affiliates or clients, unless it appears on such website, app or service, and except as otherwise discussed herein. Information Collection  Personal Information: Your provision of your Personal Information to us is completely voluntary. “Personal Information” is information that can specifically identify you. Categories of Personal Information we collect include:

• Identity Data, which includes name or other similar identifiers.
• Contact Data, which includes address, email address and telephone numbers.

Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:

• Technical Data, which includes internet protocol (IP) address, your log-in credentials.
• Usage Data, which includes information about how you use our Website and services.
• Marketing and Communications Data, which includes your preferences in receiving marketing from us.
• Profile Data, which includes your job title and company name.

IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Google Analytics	Persistent, first & third party	Used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect certain information, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for more information on Google Analytics: https://support.google.com/analytics/answer/6004245
​Facebook Pixel; Facebook Signal; Facebook Conversion Tracking	​Persistent, first & third party	​Pixel / Conversion Tracking – Conversion tracking system for ads on Facebook to our website. Signal – Surfaces relevant trends, photos, videos and posts from Facebook and Instagram for use in storytelling and reporting. Click here for more information about Facebook trackers: https://www.facebook.com/about/privacy
Mixpanel	Persistent, first & third party	​Used to collect information about how paid services users use our product. We use the infor-mation to compile reports and to help us improve the product. The cookies collect certain information, including the number of users on the product, what features they are using, and duration used. ​Click here for more information about Mixpanel: https://mixpanel.com/legal/privacy-policy/

To stop, restrict or disable the placement of cookies, please see the “Opt Out” section below.

• Clickstream Data:  As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the service. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our service to better meet consumer needs. This information will be used to improve our service.

Information Usage and Disclosure Besides using your information ourselves, we may send your information to other companies, affiliates and third parties to help us process your information for the purposes set out in this policy. Subject to the section titled “Additional EU Disclosures”, we use your information as described herein:

• Create an account on our website;
• To personalize your experience (your information helps us to better respond to your individual needs);
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
• To administer a contest, promotion, survey or other site feature;
• To send periodic emails.

Subject to the section titled “Additional EU Disclosures”, we may also share your information with third parties such as website hosting, data analysis, e-mail delivery services, and other similar services.  We may contract with third-party service providers to assist us in better understanding our site visitors. These third parties may have access to your information necessary to perform their functions, but may not use it for other purposes. We will not sell your information to any third party not affiliated with us without your consent except in connection with the sale or merger of our Company or the division responsible for such services. Additionally, we may disclose your information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) for legitimate business interests. Please note that if you specifically consent to additional uses of your information, we may use your Personal Information in a manner consistent with that consent. Finally, we reserve the right to supplement your information with information we gather from other sources which may include information we gather from online and offline sources. Security:  The security of your information is very important to us.  We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us, or information stored on the Website or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.  Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below. Data Retention: We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties. Other Websites and Social Networking Services: Our Website may contain links to other websites not maintained by us. Other websites may also reference or link to our Website.  The inclusion of a link on the Website does not imply endorsement of the linked site by us.  We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Website, or for the privacy practices of third party Internet advertising companies.  We encourage you to be aware when you leave our Website, or surf the Internet, and to read the privacy statements of each and every website that you visit. The Website may integrate with social networking services.  You understand that we do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly. Opt-Out: To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at contact@listenfirstmedia.com. We will process your request within a reasonable time after receipt. If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve Personal Information from your device without your knowledge. Additional EU Disclosures Data controller: Listen First Media LLC is the data controller of all personal data collected through our Website. To contact us, please see the section titled “Contact Us”. Legal Basis: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented to a certain use of your personal data.
• Where we need to comply with a legal or regulatory obligation.

To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary. Provision of personal data and failure to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you. Collection of personal data from third party sources: If you register for our services using Facebook or Google+, we will import your name and email from those social media sites. We may also enrich data from information provided by LinkedIn via a LinkedIn plug-in. Our services use data we receive from third party social media sites such as Facebook, Twitter and YouTube. Some of the data we receive from these third parties are publicly accessible data such as Tweets, Facebook wall posts and YouTube Channel and Video Metadata (via YouTube API Services), while others are non-public data. Data used in our services is only available to our client subscribers. Withdrawing your consent: If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at contact@listenfirstmedia.com. Data Transfer: We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR. Please contact us for more information about our data transfer methods. Use of your personal data for marketing purposes: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

• Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.

To see how you can opt out of marketing communications, please see the section titled “Opt-Out”. Data Subject Rights: If you are a situated in the EU, under the General Data Protection Regulation (“GDPR”), as a data subject, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”).
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data in certain situations.
• Request the transfer of your personal data to you or to a third party in certain situations.
• Withdraw consent at any time where we are relying on consent to process your personal data.

To exercise your rights under the GDPR, please contact us at contact@listenfirstmedia.com. Information Relating to Children Our Website is intended for ages 18 and over. We do not knowingly collect Personal Information from children.  When we become aware that Personal Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database. Changes to policy:  We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of the Website following the posting of any changes to this policy means you accept such changes. Contact:  For questions or concerns relating to this Privacy Policy or your information, we can be contacted at: 381 Park Ave S, Suite 401 New York, NY 10016 contact@listenfirstmedia.com Our privacy manager can be contacted here: contact@listenfirstmedia.com ​ If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority.