Monocl General Privacy Policy

Last revised and effective as of: June 30, 2020

This General Privacy Policy (this “Privacy Policy”) relates to information collected by Monocl AB and Monocl Company (“Monocl” “we” or “us” or “our”) through your use of the Monocl website at https://www.monocl.com/ and any subdomains thereof (the “Site”). This Policy also applies to information we may receive from or about you when we meet you at a conference, tradeshow, or similar event (an “Event”), when you sign up for or participate in a webinar presented by Monocl (whether on its own or in partnership with a commercial partner, each a “Webinar”), or when you call us by telephone or contact us by email or through chat for customer support, training, and success purposes (a “Support Call”). As used herein, (i) “you” and “your” mean a user of the Site, an individual we meet an Event, or an individual who engages in a Support Call with us; and (ii) the “Monocl Platform” means Monocl’s platform, which collects and analyzes data relating to medical, scientific, and healthcare professionals and academics (“Experts”), which is made available to Monocl’s enterprise customers in order to help such enterprise customers understand (among other things) Experts relevant to various important scientific and clinical research, key collaborations, industrial relationships, as well as Experts’ influence and relevance to our enterprise customers’ initiatives, collectively with any associated databases. For information on how Monocl processes information relating to Experts, please see the Monocl Expert Privacy Policy. Please be aware that this Privacy Policy does not apply to information of Experts that Monocl processes under the Monocl Expert Privacy Policy.

You should carefully read this Privacy Policy. To the extent you are located in the European Economic Area or the United Kingdom, or to the extent we process your personally identifiable information in the context of the activities of an establishment in the European Economic Area or United Kingdom, this Privacy Policy sets out our practices and obligations under the General Data Protection Regulation 2016/679 (the “GDPR”), to the extent applicable. As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Monocl or among our affiliates globally.

Monocl Platform

Please be aware that this Privacy Policy does not apply to personally identifiable information of Experts that Monocl processes under the Monocl Expert Privacy Policy. Additionally, if an organization with which you are associated (an “Organization”) signs up to use the Monocl Platform, your Organization may share personally identifiable information about you with us in connection with our provision of the Monocl Platform to your Organization. To the extent we process that personally identifiable information solely in order to provide the Monocl Platform to your Organization, under the GDPR, to the extent applicable, we will act as a processor (as defined in the GDPR) on behalf of your Organization in respect of that personally identifiable information; this Privacy Policy will not apply to the processing of that personally identifiable information and your Organization will act as a controller (as defined in the GDPR) in respect of that personally identifiable information and is responsible for having a lawful basis for processing that information, for acting in all matters in accordance with all applicable laws, and for providing you with all requisite information as required by applicable law. To the extent we process your personally identifiable information for any other lawful business purpose of ours, under the GDPR, to the extent applicable, we will act as a controller of such personally identifiable information and this Privacy Policy will apply to the processing of such personally identifiable information. For clarification but not limitation, information we process for our legitimate business purposes, such as for product development or sales and marketing, is not processed solely on behalf of your Organization.

This Privacy Policy serves to notify you of the following:

What information about me is collected?
Where and when is information collected (including through the use of cookies and action tags)?
Does Monocl collect information from children under 13 years of age?
What does Monocl do with the information it collects?
When does Monocl disclose information to third parties?
Does this Privacy Policy apply when I link to other websites or services?
Is the information collected under this Privacy Policy secure?
Could my information be transferred to other countries?
For how long will my personally identifiable information be kept?
What choices do I have regarding my personally identifiable information?
How will I know if there are any changes to this Privacy Policy?
Who do I contact if I have any privacy questions?
Special Notice for California Residents.

1. WHAT INFORMATION ABOUT ME IS COLLECTED?

Depending on your use of the Site or our interactions with you, we may collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information

As used in this Privacy Policy, “personally identifiable information” means information that identifies you, your household, or your device, could be used to identify you, your household, or your device, or could be used to contact you. Such information may include your name, e-mail address, job title, company, Support chat transcripts, city, country, continent, postal address, IP address, online identifier, company size, department, prospective use-cases, interests, telephone number, and any other information you may choose to share with us. Personally identifiable information amounts to ‘personal data’ for the purposes of and as defined in the GDPR. All references to personally identifiable information shall be deemed to include ‘personal data’ as defined and used in the GDPR (to the extent applicable).

Non-Personally Identifiable Information

Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including non-identifiable demographic information, language, internet service provider, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, the duration of your visit, location (city, country, continent), operating system, domain names, and statistical data involving the use of the Site. We also collect aggregated statistics connected to support issues. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences) in a way that would not enable you to be identified.

2. WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We collect personally identifiable information that you submit to us, including when you subscribe to our newsletter, request a demo, or if you engage in an instant message “chat” with one of our representatives on the Site. We may receive personally identifiable information from or about you when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. We may also receive lists of contact information from commercial partners with whom we partner to present Webinars. We may also receive information about you from other third parties, such as search information providers, providers of meta-data about Site visitors, and lead generation services, and we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites.

Cookies and Action Tags.

We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Site (such as saving time by not having to reenter your name each time you use the Site), to allow us to statistically monitor how you are using the Site to help us improve our offerings, or to determine the popularity of certain content.

Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Site, including e-mail sent on our behalf, may contain action tags.

For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy available at https://www.monocl.com/cookie-policy/.

Log Files.

We may also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other statistical data involving the use of the Site. This information may be used to analyze trends, to administer the Site, to monitor the use of the Site, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Site and evaluating and improving the Site in general.

3. DOES MONOCL COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Site is not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13.

4. WHAT DOES MONOCL DO WITH THE INFORMATION IT COLLECTS?

We will use your personally identifiable information to the extent that the law allows us to do so. Pursuant to the GDPR, legal bases for our processing your personally identifiable information may include (without limitation):

  • (a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
  • (b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Site, Support Calls, or otherwise); and/or
  • (c) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing or marketing the Site and your interests or fundamental rights and freedoms do not override those legitimate interests.

We use the information collected to provide the Site to you, to provide a Webinar that you sign up for or participate in, to help us understand who uses the Site and the Monocl Platform (and how), for internal operations such as operating and improving the Site and the Monocl Platform, to contact you for customer service and for Support Call purposes, to facilitate our marketing activities, and, unless you opt out (to the extent permitted by applicable law), so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you. In particular, unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may send you electronic newsletters, contact you about the Site, the Monocl Platform, products, services, information and news that may be of interest to you, and provide you with targeted feedback. Some of this information may be tailored to you based on your usage of the Site. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy@monocl.com.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Site. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Site.

5. WHEN DOES MONOCL DISCLOSE INFORMATION TO THIRD PARTIES?

We generally disclose information we gather under this Privacy Policy to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Site, the Monocl Platform, or the general public.

Analytics and Advertisement Targeting Service Providers.

When users use our Site, third-party analytics and advertisement targeting service providers may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include providers of advertisement targeting services and providers of analytics products or services (including vendors, analytics and advertisement targeting service providers, and website tracking services). Please note in particular that the Site uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at https://www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products, such as hosting and maintaining the Site, providing fraud screening, and developing applications for the Site. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Site, including your personally identifiable information.

Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of Monocl or any of its Corporate Affiliates (as defined below), or that portion of Monocl or any of its Corporate Affiliates to which the Site relates or to which any other activities of Monocl that are subject to this Privacy Policy relate, or in connection with a strategic investment by a third party in Monocl, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.

We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Monocl AB or Monocl Company, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

Our Site may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Site. A link to a third party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service.

7. IS THE INFORMATION COLLECTED UNDER THIS PRIVACY POLICY SECURE?

We use reasonable efforts designed to ensure that the information we have collected about you is secure. In order to prevent unauthorized access to or unauthorized alteration, disclosure or destruction of data, we have put in place commercially reasonable physical, electronic and managerial procedures designed to safeguard and secure the information we collect. Such measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personally identifiable information.

8. COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Personally identifiable information collected under this Privacy Policy may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Site may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. Without limitation of the foregoing, you hereby expressly grant consent to the Monocl to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for personally identifiable information (as determined by the European Commission, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by the GDPR: whenever we transfer your personal data (as defined in the GDPR) to an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Economic Area under the GDPR or, with respect to transfers of personal data to the United States, we may rely on the Privacy Shield certification of the recipient; and, if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.

9. FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT?

We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.

To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. WHAT CHOICES DO I HAVE REGARDING MY PERSONALLY IDENTIFIABLE INFORMATION?

We generally use personally identifiable information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must “opt in” and give us permission to use your personally identifiable information for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy@monocl.com.

Under certain circumstances and in compliance with the GDPR, you may have the right to:

Request access to your personally identifiable information (commonly known as ‘subject access request’). This enables you to receive a copy of the personally identifiable information we hold about you and to check that we are lawfully processing it;

Request correction of the personally identifiable information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

Request erasure of your personally identifiable information. This enables you to ask us to delete or remove your personally identifiable information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personally identifiable information in certain circumstances;

Object to processing of your personally identifiable information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

Request the restriction of processing of your personally identifiable information. This enables you to ask us to suspend the processing of your personally identifiable information, for example, if you want us to establish its accuracy or the reason for processing it;

Request the transfer of your personally identifiable information to another party; and

Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). If you have any complaints about the way we process your personally identifiable information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your personally identifiable information, object to the processing of your personally identifiable information, or request that we transfer a copy of your personally identifiable information to another party, please contact privacy@monocl.com.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you access or making corrections.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

DO NOT TRACK

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

11. HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. We encourage you to check this page periodically for any changes; the date for the latest updated version of this Privacy Policy is specified at the top of this Privacy Policy. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Site. Your continued use of the Site following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

12. WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

Caroline Pamp is the Data Protection Officer at Monocl. If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Data Protection Officer in any of the following ways:

By e-mail:
privacy@monocl.com

By postal mail or courier:
Attn: Data Protection Officer
Monocl AB
Redegatan 1B
426 77 Västra Frölunda
Sweden

13. SPECIAL NOTICE FOR CALIFORNIA RESIDENTS.

This Section 13 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA. This Section 13 shall apply to you only if you are a California resident.

If an Organization with which you are associated signs up to use the Monocl Platform, your Organization may share consumer information (as defined below) about you with us in connection with our provision of the Monocl Platform to your Organization. To the extent we process such consumer information solely in order to provide the Monocl Platform to your Organization, under the CCPA, to the extent applicable, we will act as a service provider (as defined in the CCPA) on behalf of your Organization in respect of that consumer information; this Privacy Policy will not apply to the processing of that consumer information and your Organization will act as a business (as defined in the CCPA) in respect of that consumer information. The business is responsible for acting in all matters in accordance with all applicable laws and providing you with all requisite information as required by applicable law. To the extent we process your consumer information for any other lawful business purpose of ours, under the CCPA, to the extent applicable, we will act as a business with respect to such consumer information and this Privacy Policy will apply to the processing of such consumer information. For clarification but not limitation, information we process for our legitimate business purposes, such as for product development or sales and marketing, is not processed solely on behalf of your Organization.

As used in this Section 13, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration.

“Selling” does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through the Site, provided the third party does not also sell the consumer information, (iii) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Monocl’s behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (iv) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Monocl, provided that information is used or shared consistently with the CCPA.

Where noted in this Privacy Policy, until January 1, 2021, the CCPA exempts consumer information reflecting a written or verbal business-to-business communication (“B2B consumer information”) from some its requirements, provided that such exemptions shall not apply from and after January 1, 2021.

13.1 Consumer Information Collected: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households (“consumer information”). Consumer information does not include deidentified or aggregated information or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, with respect to the activities covered by this Privacy Policy, we have collected the following categories of consumer information from California residents, households or devices within the last twelve (12) months:

Category Examples Business or commercial purposes for which we collect, use, and sell consumer information
A. Identifiers. Name, e-mail address, job title, company, Support chat transcripts, city, country, continent, postal address, IP address, online identifier, company size, department, prospective use-cases, interests, telephone number, and any other information you may choose to share with us.
  • To provide the Site to you;
  • To provide a Webinar that you sign up for or participate in;
  • To help us understand who uses the Site and the Monocl Platform (and how);
  • For internal operations such as operating and improving the Site and the Monocl Platform;
  • To contact you for customer service and for Support Call purposes; and
  • To facilitate our marketing activities and to market the Monocl Platform.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name, telephone number, postal address, and job title.
  • To provide the Site to you;
  • To provide a Webinar that you sign up for or participate in;
  • To help us understand who uses the Site and the Monocl Platform (and how);
  • For internal operations such as operating and improving the Site and the Monocl Platform;
  • To contact you for customer service and for Support Call purposes; and
  • To facilitate our marketing activities and to market the Monocl Platform.
C. Internet or other similar network activity. IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, and statistical data involving the use of the Site.
  • To provide the Site to you;
  • To provide a Webinar that you sign up for or participate in;
  • To help us understand who uses the Site and the Monocl Platform (and how);
  • For internal operations such as operating and improving the Site and the Monocl Platform;
  • To contact you for customer service and for Support Call purposes; and
  • To facilitate our marketing activities and to market the Monocl Platform.
D. Professional or employment-related information. Job title.
  • To provide the Site to you;
  • To provide a Webinar that you sign up for or participate in;
  • To help us understand who uses the Site and the Monocl Platform (and how);
  • For internal operations such as operating and improving the Site and the Monocl Platform;
  • To contact you for customer service and for Support Call purposes; and
  • To facilitate our marketing activities and to market the Monocl Platform.

13.2 Use of Consumer Information; Categories of Sources: We use consumer information for the business or commercial purposes described in the table above and in the manner described in Sections 2 and 4 of this Privacy Policy with respect to personally identifiable information. We also receive information that is otherwise collected when you use the Site, including as described in Section 2. Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us, including when you subscribe to our newsletter, request a demo, or if you engage in an instant message “chat” with one of our representatives on the Site. We may receive consumer information from or about you when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. We may also receive lists of contact information from commercial partners with whom we partner to present Webinars. We may also receive information about you from other third parties, such as search information providers, providers of meta-data about Site visitors, and lead generation services, and we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites.

13.3 Disclosures of Consumer Information for a Business or Commercial Purpose: Monocl may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Section 5 of this Privacy Policy with respect to personally identifiable information. In the preceding twelve (12) months, Monocl has disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the following categories of third parties (as further described in Section 5 of this Privacy Policy):

  • 13.3.1 Outside Contractors; and
  • 13.3.2 Corporate Affiliates.

In the preceding twelve (12) months, Monocl has disclosed internet or other similar network activity to the categories of third parties referenced in Section 5 of this Privacy Policy and captioned as “Analytics and Advertisement Targeting Service Providers”.

13.4 Sales of Consumer Information: In the preceding twelve (12) months, Monocl has not sold, nor does it or will it sell, consumer information that is subject to this Privacy Policy; however, please see Monocl’s Expert Privacy Policy for details regarding Monocl’s collection and use (including sale) of publicly available information relating to Experts, including sharing of such publicly available information relating to Experts with Monocl’s enterprise customers.

13.5 California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their consumer information. This Section 13.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

  • 13.5.1 Access to Specific Information and Data Portability Rights: You may have the right to request that Monocl disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 13.6 below), to the extent required by the CCPA, we will disclose to you:
    • 13.5.1.1 The categories of consumer information we collected about you.
    • 13.5.1.2 The categories of sources for the consumer information we collected about you.
    • 13.5.1.3 Our business or commercial purpose for collecting that consumer information.
    • 13.5.1.4 The categories of third parties with whom we share that consumer information.
    • 13.5.1.5 The specific pieces of consumer information we collected about you (also called a data portability request).
    • 13.5.1.6 If we disclosed your consumer information for a business purpose, a list disclosing disclosures for a business purpose, identifying the consumer information categories that each category of recipient obtained.

We will not provide the foregoing access and data portability rights for B2B consumer information prior to January 1, 2021.

  • 13.5.2 Deletion Request Rights: You have the right to request that Monocl delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 13.6 below (“verifiable consumer request”), we will delete (and direct our service providers to delete) your consumer information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    • 13.5.2.1 Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
    • 13.5.2.2 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • 13.5.2.3 Debug products or services to identify and repair errors that impair existing intended functionality.
    • 13.5.2.4 Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • 13.5.2.5 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • 13.5.2.6 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • 13.5.2.7 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • 13.5.2.8 Comply with a legal obligation.
    • 13.5.2.9 Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will not provide the foregoing deletion rights for B2B consumer information prior to January 1, 2021.

13.6 Exercising Access, Data Portability, and Deletion Rights:

  • 13.6.1 To exercise the access, data portability, and deletion rights described in Section 13.5 above, please submit a verifiable consumer request to us by either: (1) calling us at 888-211-9007; (2) visiting link; or (3) contacting us in accordance with Section 12. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. In the event you make a request under this Section 13, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you.
  • 13.6.2 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

13.7 Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:

  • 13.7.1 Denying you goods or services.
  • 13.7.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • 13.7.3 Providing you a different level or quality of goods or services.
  • 13.7.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.