POPSUGAR Data Processing Addendum
This Data Processing Addendum (the "Addendum") forms part of the written or electronic agreement(s) between Group Nine Media, Inc. and/or any of its Affiliates (collectively, "Group Nine"), and the Agency (if any), in relation to the advertising client (the "Client") designated in the applicable insertion order(s) (each, an "IO") and any addendum or other terms applicable thereto (collectively, the "Agreement"), in connection with one or more advertising campaigns for Client (each a "Campaign"), to reflect the parties' agreement with regard to the Processing of Personal Data (as each is defined below) in connection with the Agreement. All capitalized terms not defined herein shall have the meaning set forth in the Agreement.
In the course of running the Campaign, Group Nine may allow Client and/or its authorized Client Vendors to collect certain Personal Data from end users on Group Nine's websites and other properties as identified in the IO (the "Group Nine Properties"). By signing the Agreement, Client enters into this Addendum on behalf of itself and its Affiliates (as defined below), if and to the extent such Affiliates receive and/or Process Personal Data in connection with the Agreement.
The parties agree to comply with the following provisions with respect to any Personal Data, each acting reasonably and in good faith.
1. DEFINITIONS.
(a) "Affiliate" means entity that owns or controls, is owned or controlled by, or is or under common control or ownership with Group Nine Media, Inc. or Client (as applicable), where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise.
(b) "Data Controller" means the entity that determines the purposes and means of the Processing of Personal Data.
(c) "Data Processor" means the entity which Processes Personal Data on behalf of a Data Controller.
(d) "Data Protection Laws and Regulations" means all applicable laws and regulations relating to privacy or the use or processing of data relating to natural persons, including: (a) the EU Directives 95/46/EC and 2002/58/EC (as amended by 2009/139/EC) and any legislation implementing or made pursuant to such directives, including (in the UK) the Data Protection Act 1998 and the Privacy and Electronic Communications (the "EC Directive"); and (b) from May 25, 2018, the GDPR; and (c) any laws or regulations ratifying, implementing, adopting, supplementing or replacing the GDPR and/or the EC Directive; in each case, to the extent in force, and as such are updated, amended or replaced from time to time.
(e) "Data Subject" means the identified or identifiable natural person to whom Personal Data relates.
(f) "Data Subject Request" means a request from a Data Subject to exercise the Data Subject's rights under Data Protection Laws and Regulations in relation to Personal Data Processed by either party or their vendors in connection with the Agreement, including with respect to: (a) access, rectification and/or erasure (i.e., "right to be forgotten") of their Personal Data; (b) restriction of or objection to Processing; (c) data portability; or (d) automated decision-making (including profiling).
(g) "EEA" means the European Economic Area.
(h) "GDPR" means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
(i) "Personal Data" means any information relating to (i) an identified or identifiable natural person located in the European Union; or (ii) an identified or identifiable legal entity located in the European Union (where such information is protected similarly as personal data under applicable Data Protection Laws and Regulations).
(j) "GROUP Nine Data" means any Personal Data that is collected or Processed by Group Nine or its vendors in connection with the Agreement that is not provided by Client.
(k) "Process" or "Processed" or "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, including, but not limited to, collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
(l) "Regulator" means any person or regulatory body with responsibility for monitoring and/or enforcing compliance with the Data Protection Laws and Regulations.
(m) "Standard Contractual Clauses" means the agreement(s) executed by and between Group Nine and Client (if applicable), attached hereto as Schedule 1, pursuant to the European Commission's decision (C(2010)593) of February 5, 2010 on Standard Contractual Clauses for the transfer of Personal Data to Controllers established in countries which do not ensure an adequate level of data protection.
2. PROCESSING OF PERSONAL DATA.
(a) Roles of the Parties. For the purpose of this Addendum, Group Nine is a Data Controller of the Group Nine Data and Client is an independent Data Controller of any data Client or any of the Client Vendors collect on the Group Nine Properties. Nothing in this Addendum or the Agreement is intended to or shall create a relationship of joint Data Controller between Client and Group Nine. Except as otherwise expressly set forth in the Agreement or this Addendum, Group Nine's use of Personal Data shall not be subject to Client's policies and Client's use of Personal Data shall not be subject to Group Nine's policies.
(b) Compliance with Applicable Laws. Each party agrees that Personal Data will be accessed, Processed and/or transferred in accordance with Data Protection Laws and Regulations. In complying with the Data Protection Laws and Regulations, each Party shall, without limitation:
(i) Implement and maintain at all times all appropriate security measures in relation to the processing of Personal Data;(ii) Maintain a record of all Processing activities carried out in connection with the Agreement; and(iii) Not knowingly do anything or permit anything to be done which might lead to a breach by the other party of the Data Protection Laws and Regulations.
(c) Client Vendors. Client may engage third-party vendors to Process Personal Data collected on the Group Nine Properties solely as set forth in the Agreement or with the prior written approval of Group Nine ("Client Vendors"). Client will be responsible for any acts, errors, or omissions of Client Vendors in violation of Data Protection Laws and Regulations, or that cause Client to breach any of its obligations under this Addendum.
(d) Cooperation. Each party shall (and, with respect to Client, shall ensure that all Client Vendors shall) co-operate with the other party and provide such information and assistance as the other party may reasonably require to enable the other party to comply with its obligations under Data Protection Laws.
(e) User Consents. Client agrees that it will not, and the Client Vendors will not, collect any Personal Data from users of the Group Nine Properties, including, without limitation, by setting cookies or similar technology on the browsers or devices of Data Subjects, unless each Data Subject has first given consent as required by and in compliance with Data Protection Laws and Regulations. Client acknowledges that Group Nine uses IAB TCF 2.0 to obtain and pass user consents to downstream advertising technology vendors. Client agrees that it will only engage Client Vendors that are listed in the IAB TCF 2.0 Global Vendor List and will ensure that Client Vendors honor the consent strings passed through the TCF.
3. DATA SUBJECT RIGHTS; REGULATORY REQUESTS AND ENFORCEMENT.
(a) Taking into account the nature of the Processing, each party shall provide the other party with full co-operation and assistance in responding to any Data Subject Request that relates to Personal Data Processed in connection with the Agreement by implementing reasonable and appropriate technical and organizational measures for the fulfillment of obligations to respond to a Data Subject Request or investigations and requests for information relating to the Processing of Personal Data pursuant to the Agreement from any Regulator. Each party shall provide commercially reasonable efforts to assist the other party in responding to Data Subject Requests as requested by the other party. For avoidance of doubt, the party which receives the Data Subject Request shall be responsible for responding to such request.
(b) If either party receives any complaint, notice or communication from a Regulator or other third party which relates directly or indirectly to the Processing of Personal Data in connection with the Agreement or to either party's compliance with the Data Protection Laws and Regulations in connection with the Agreement, the party receiving such inquiry shall notify the other party as soon as reasonably practicable and it shall provide the other party with reasonable co-operation and assistance in relation to any such complaint, notice or communication.
(c) Subject to paragraph 4(b), neither party shall take any action in relation to any complaint, notice or communication where it relates to the other party's processing of Personal Data as a Data Controller without prior written notice to the other party and providing the other party with a reasonable opportunity to contribute to the response to mitigate the impact of the action on the other party.
(d) Each party agrees to provide the other party with reasonable cooperation and assistance needed in connection with any data protection impact assessments and any prior consultations with Regulators or other competent data privacy authorities, which the other party reasonably considers to be required for it to fulfil its obligations pursuant to the GDPR or any other Data Protection Laws and Regulations.
4. SECURITY.
Each party shall (and, with respect to Client, shall ensure that Client Vendors shall) implement and maintain a written information security program with data security measures appropriate to the risks of such party's Processing of Personal Data.
5. RESTRICTED TRANSFER.
(a) Standard Contractual Clauses. Where Personal Data will be transferred by Client or Client Vendors to a country not recognized by the European Commission as providing an adequate level of protection for Personal Data as described in the EU Data Protection Directive (95/46/EC), the following terms apply:
(i) The Standard Contractual Clauses attached as Schedule 1 shall apply and form part of this Addendum, with (subject to the following) Group Nine acting as the Data Exporter (as defined in the Standard Contractual Clauses), to the Client as Data Importer (as defined in the Standard Contractual Clauses). For purposes of the Standard Contractual Clauses, the Client's address shall be the address of the Data Importer, and its country of residence shall be the country of the Data Importer. Upon execution of this Addendum, both parties shall be deemed to have accepted the Standard Contractual Clauses, and the Standard Contractual Clauses shall become legally binding. The contact point for the receiving party as the Data Importer for purposes of Annex B of the Standard Contractual Clauses shall be the designated contact the Client set forth in the Agreement.
(ii) In the event of any conflict or inconsistency between the Agreement (including this Addendum) and the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.
(b) Transfers to Vendors. In the event that Client transfers Personal Data to Client Vendors outside the EAA or allows Client Vendors located outside of the EEA to collect Personal Data directly from end users of the Group Nine Properties, Client is solely responsible for ensuring that it takes all measures necessary to ensure that such transfer is in compliance with all Data Protection Laws and Regulations.
(c) Invalidation of Transfer Mechanism. If Personal Data is transferred outside the EEA in accordance with this Addendum and either (a) the means by which adequate protection for the transfer is achieved ceases to be valid; or (b) any supervisory authority or Regulator requires transfers of Personal Data pursuant to such transfer mechanism to be suspended, this Section 6(c) applies. In such event, the parties will work together in good faith to amend the Agreement and/or this Addendum to implement a legally-compliant transfer mechanism.
6. LIMITATION OF LIABILITY.
Each party's and its Affiliates' liability arising out of or related to this Addendum (whether in contract, tort or under any other theory of liability) is not subject to any limitations of liability set forth in the Agreement, including if applicable, the section(s) entitled "Limitation of Liability" of the Agreement, and any reference in such section to the liability of a party means that party and its Affiliates in the aggregate.
7. INDEMNITY.
Notwithstanding anything in the Agreement to the contrary, each party will indemnify the other party and such other party's Affiliates, and each of their respective directors, officers, employees and agents in respect of any third-party claims, liabilities, damages, administrative fine, losses or costs incurred by the other party or its Affiliates as a result of any act or omission of the indemnifying party in breach of this Addendum or violation of Data Protection Laws and Regulations.
SCHEDULE 1 – STANDARD CONTRACTUAL CLAUSES
Standard contractual clauses for the transfer of personal data from the Community to third countries (controller to controller transfers)
Data transfer agreement
between
Group Nine Media, Inc. (name)
568 Broadway, 10th Floor, New York, NY 10012 United States (address and country of establishment)
hereinafter "data exporter"
and
Client and/or its Affilites (as described in the attached Data Processing Addendum) (name)
Address shall be the address of the Client as described in the attached Data Processing Addendum (address and country of establishment)
hereinafter "data importer"
each a "party"; together "the parties".
Definitions
For the purposes of the clauses:
a) "personal data", "special categories of data/sensitive data", "process/processing", "controller", "processor", "data subject" and "supervisory authority/authority" shall have the same meaning as in Directive 95/46/EC of 24 October 1995 (whereby "the authority" shall mean the competent data protection authority in the territory in which the data exporter is established);
b) "the data exporter" shall mean the controller who transfers the personal data;
c) "the data importer" shall mean the controller who agrees to receive from the data exporter personal data for further processing in accordance with the terms of these clauses and who is not subject to a third country's system ensuring adequate protection;
d) "clauses" shall mean these contractual clauses, which are a free-standing document that does not incorporate commercial business terms established by the parties under separate commercial arrangements.
The details of the transfer (as well as the personal data covered) are specified in Annex B, which forms an integral part of the clauses.
I. Obligations of the data exporter
The data exporter warrants and undertakes that:
a) The personal data have been collected, processed and transferred in accordance with the laws applicable to the data exporter.
b) It has used reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses.
c) It will provide the data importer, when so requested, with copies of relevant data protection laws or references to them (where relevant, and not including legal advice) of the country in which the data exporter is established.
d) It will respond to enquiries from data subjects and the authority concerning processing of the personal data by the data importer, unless the parties have agreed that the data importer will so respond, in which case the data exporter will still respond to the extent reasonably possible and with the information reasonably available to it if the data importer is unwilling or unable to respond. Responses will be made within a reasonable time.
e) It will make available, upon request, a copy of the clauses to data subjects who are third party beneficiaries under clause III, unless the clauses contain confidential information, in which case it may remove such information. Where information is removed, the data exporter shall inform data subjects in writing of the reason for removal and of their right to draw the removal to the attention of the authority. However, the data exporter shall abide by a decision of the authority regarding access to the full text of the clauses by data subjects, as long as data subjects have agreed to respect the confidentiality of the confidential information removed. The data exporter shall also provide a copy of the clauses to the authority where required.
II. Obligations of the data importer
The data importer warrants and undertakes that:
a) It will have in place appropriate technical and organisational measures to protect the personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and which provide a level of security appropriate to the risk represented by the processing and the nature of the data to be protected.
b) It will have in place procedures so that any third party it authorises to have access to the personal data, including processors, will respect and maintain the confidentiality and security of the personal data. Any person acting under the authority of the data importer, including a data processor, shall be obligated to process the personal data only on instructions from the data importer. This provision does not apply to persons authorised or required by law or regulation to have access to the personal data.
c) It has no reason to believe, at the time of entering into these clauses, in the existence of any local laws that would have a substantial adverse effect on the guarantees provided for under these clauses, and it will inform the data exporter (which will pass such notification on to the authority where required) if it becomes aware of any such laws.
d) It will process the personal data for purposes described in Annex B, and has the legal authority to give the warranties and fulfil the undertakings set out in these clauses.
e) It will identify to the data exporter a contact point within its organisation authorised to respond to enquiries concerning processing of the personal data, and will cooperate in good faith with the data exporter, the data subject and the authority concerning all such enquiries within a reasonable time. In case of legal dissolution of the data exporter, or if the parties have so agreed, the data importer will assume responsibility for compliance with the provisions of clause I(e).
f) At the request of the data exporter, it will provide the data exporter with evidence of financial resources sufficient to fulfil its responsibilities under clause III (which may include insurance coverage).
g) Upon reasonable request of the data exporter, it will submit its data processing facilities, data files and documentation needed for processing to reviewing, auditing and/or certifying by the data exporter (or any independent or impartial inspection agents or auditors, selected by the data exporter and not reasonably objected to by the data importer) to ascertain compliance with the warranties and undertakings in these clauses, with reasonable notice and during regular business hours. The request will be subject to any necessary consent or approval from a regulatory or supervisory authority within the country of the data importer, which consent or approval the data importer will attempt to obtain in a timely fashion.
h) It will process the personal data, at its option, in accordance with:
i. the data protection laws of the country in which the data exporter is established, or
ii. the relevant provisions of any Commission decision pursuant to Article 25(6) of Directive 95/46/EC, where the data importer complies with the relevant provisions of such an authorisation or decision and is based in a country to which such an authorisation or decision pertains, but is not covered by such authorisation or decision for the purposes of the transfer(s) of the personal data, or
iii. the data processing principles set forth in Annex A.
Data importer to indicate which option it selects:....................................................
Initials of data importer:..................................................................................... ;
i) It will not disclose or transfer the personal data to a third party data controller located outside the European Economic Area (EEA) unless it notifies the data exporter about the transfer and
i. the third party data controller processes the personal data in accordance with a Commission decision finding that a third country provides adequate protection, or
ii. the third party data controller becomes a signatory to these clauses or another data transfer agreement approved by a competent authority in the EU, or
iii. data subjects have been given the opportunity to object, after having been informed of the purposes of the transfer, the categories of recipients and the fact that the countries to which data is exported may have different data protection standards, or
iv. with regard to onward transfers of sensitive data, data subjects have given their unambiguous consent to the onward transfer
III. Liability and third party rights
a) Each party shall be liable to the other parties for damages it causes by any breach of these clauses. Liability as between the parties is limited to actual damage suffered. Punitive damages (i.e. damages intended to punish a party for its outrageous conduct) are specifically excluded. Each party shall be liable to data subjects for damages it causes by any breach of third party rights under these clauses. This does not affect the liability of the data exporter under its data protection law.
b) The parties agree that a data subject shall have the right to enforce as a third party beneficiary this clause and clauses I(b), I(d), I(e), II(a), II(c), II(d), II(e), II(h), II(i), III(a), V, VI(d) and VII against the data importer or the data exporter, for their respective breach of their contractual obligations, with regard to his personal data, and accept jurisdiction for this purpose in the data exporter's country of establishment. In cases involving allegations of breach by the data importer, the data subject must first request the data exporter to take appropriate action to enforce his rights against the data importer; if the data exporter does not take such action within a reasonable period (which under normal circumstances would be one month), the data subject may then enforce his rights against the data importer directly. A data subject is entitled to proceed directly against a data exporter that has failed to use reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses (the data exporter shall have the burden to prove that it took reasonable efforts).
IV. Law applicable to the clauses
These clauses shall be governed by the law of the country in which the data exporter is established, with the exception of the laws and regulations relating to processing of the personal data by the data importer under clause II(h), which shall apply only if so selected by the data importer under that clause.
V. Resolution of disputes with data subjects or the authority
a) In the event of a dispute or claim brought by a data subject or the authority concerning the processing of the personal data against either or both of the parties, the parties will inform each other about any such disputes or claims, and will cooperate with a view to settling them amicably in a timely fashion.
b) The parties agree to respond to any generally available non-binding mediation procedure initiated by a data subject or by the authority. If they do participate in the proceedings, the parties may elect to do so remotely (such as by telephone or other electronic means). The parties also agree to consider participating in any other arbitration, mediation or other dispute resolution proceedings developed for data protection disputes.
c) Each party shall abide by a decision of a competent court of the data exporter's country of establishment or of the authority which is final and against which no further appeal is possible.
VI. Termination
a) In the event that the data importer is in breach of its obligations under these clauses, then the data exporter may temporarily suspend the transfer of personal data to the data importer until the breach is repaired or the contract is terminated.
b) In the event that:
i. the transfer of personal data to the data importer has been temporarily suspended by the data exporter for longer than one month pursuant to paragraph (a);
ii. compliance by the data importer with these clauses would put it in breach of its legal or regulatory obligations in the country of import;
iii. the data importer is in substantial or persistent breach of any warranties or undertakings given by it under these clauses;
iv. a final decision against which no further appeal is possible of a competent court of the data exporter's country of establishment or of the authority rules that there has been a breach of the clauses by the data importer or the data exporter; or
v. a petition is presented for the administration or winding up of the data importer, whether in its personal or business capacity, which petition is not dismissed within the applicable period for such dismissal under applicable law; a winding up order is made; a receiver is appointed over any of its assets; a trustee in bankruptcy is appointed, if the data importer is an individual; a company voluntary arrangement is commenced by it; or any equivalent event in any jurisdiction occurs
then the data exporter, without prejudice to any other rights which it may have against the data importer, shall be entitled to terminate these clauses, in which case the authority shall be informed where required. In cases covered by (i), (ii), or (iv) above the data importer may also terminate these clauses.
c) Either party may terminate these clauses if (i) any Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC (or any superseding text) is issued in relation to the country (or a sector thereof) to which the data is transferred and processed by the data importer, or (ii) Directive 95/46/EC (or any superseding text) becomes directly applicable in such country.
d) The parties agree that the termination of these clauses at any time, in any circumstances and for whatever reason (except for termination under clause VI(c)) does not exempt them from the obligations and/or conditions under the clauses as regards the processing of the personal data transferred.
VII. Variation of these clauses
The parties may not modify these clauses except to update any information in Annex B, in which case they will inform the authority where required. This does not preclude the parties from adding additional commercial clauses where required.
VIII. Description of the Transfer
The details of the transfer and of the personal data are specified in Annex B. The parties agree that Annex B may contain confidential business information which they will not disclose to third parties, except as required by law or in response to a competent regulatory or government agency, or as required under clause I(e). The parties may execute additional annexes to cover additional transfers, which will be submitted to the authority where required. Annex B may, in the alternative, be drafted to cover multiple transfers.
Dated:..........................................
FOR DATA IMPORTER FOR DATA EXPORTER
................................................... Nadav Zamir, Senior Director & Data Privacy Officer
................................................... Group Nine Media, Inc.
................................................... 568 Broadway, 10th Floor
................................................... New York, NY 10012, United States
ANNEX A
DATA PROCESSING PRINCIPLES
1. Purpose limitation: Personal data may be processed and subsequently used or further communicated only for purposes described in Annex B or subsequently authorised by the data subject.
2. Data quality and proportionality: Personal data must be accurate and, where necessary, kept up to date. The personal data must be adequate, relevant and not excessive in relation to the purposes for which they are transferred and further processed.
3. Transparency: Data subjects must be provided with information necessary to ensure fair processing (such as information about the purposes of processing and about the transfer), unless such information has already been given by the data exporter.
4. Security and confidentiality: Technical and organisational security measures must be taken by the data controller that are appropriate to the risks, such as against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, presented by the processing. Any person acting under the authority of the data controller, including a processor, must not process the data except on instructions from the data controller.
5. Rights of access, rectification, deletion and objection: As provided in Article 12 of Directive 95/46/EC, data subjects must, whether directly or via a third party, be provided with the personal information about them that an organisation holds, except for requests which are manifestly abusive, based on unreasonable intervals or their number or repetitive or systematic nature, or for which access need not be granted under the law of the country of the data exporter. Provided that the authority has given its prior approval, access need also not be granted when doing so would be likely to seriously harm the interests of the data importer or other organisations dealing with the data importer and such interests are not overridden by the interests for fundamental rights and freedoms of the data subject. The sources of the personal data need not be identified when this is not possible by reasonable efforts, or where the rights of persons other than the individual would be violated. Data subjects must be able to have the personal information about them rectified, amended, or deleted where it is inaccurate or processed against these principles. If there are compelling grounds to doubt the legitimacy of the request, the organisation may require further justifications before proceeding to rectification, amendment or deletion. Notification of any rectification, amendment or deletion to third parties to whom the data have been disclosed need not be made when this involves a disproportionate effort. A data subject must also be able to object to the processing of the personal data relating to him if there are compelling legitimate grounds relating to his particular situation. The burden of proof for any refusal rests on the data importer, and the data subject may always challenge a refusal before the authority.
6. Sensitive data: The data importer shall take such additional measures (e.g. relating to security) as are necessary to protect such sensitive data in accordance with its obligations under clause II.
7. Data used for marketing purposes: Where data are processed for the purposes of direct marketing, effective procedures should exist allowing the data subject at any time to "opt-out" from having his data used for such purposes.
8. Automated decisions: For purposes hereof "automated decision" shall mean a decision by the data exporter or the data importer which produces legal effects concerning a data subject or significantly affects a data subject and which is based solely on automated processing of personal data intended to evaluate certain personal aspects relating to him, such as his performance at work, creditworthiness, reliability, conduct, etc. The data importer shall not make any automated decisions concerning data subjects, except when:
a) i. such decisions are made by the data importer in entering into or performing a contract with the data subject, and
ii. the data subject is given an opportunity to discuss the results of a relevant automated decision with a representative of the parties making such decision or otherwise to make representations to that parties.
or
b) where otherwise provided by the law of the data exporter.
ANNEX B
DESCRIPTION OF THE TRANSFER
Data subjects
The personal data transferred concern the following categories of data subjects:
End users of Group Nine Properties (as defined in the Addendum).
Purposes of the transfer(s)
The transfer is made for the following purposes:
As set forth in the Agreement.
Categories of data
The personal data transferred concern the following categories of data:
The categories of Personal Data as defined and set forth in the Agreement.
Recipients
The personal data transferred may be disclosed only to the following recipients or categories of recipients:
The Client Vendors, as defined in and subject to the terms of the Addendum.
Sensitive data (if appropriate)
The personal data transferred concern the following categories of sensitive data:
Not applicable.
Data protection registration information of data exporter (where applicable)
Not applicable.
Additional useful information (storage limits and other relevant information)
Not applicable.
Contact points for data protection enquiries
Data importer Data exporter
Client (as specified in the Agreement) Nadav Zamir, Senior Director & Data Privacy Officer
………………………………………… …… Group Nine Media, Inc.
………………………………………… …… 568 Broadway, 10th Floor
New York, NY 10012, United States
