PRIVACY POLICY

 

Last Updated: December 10, 2021

 

 

This privacy policy (the “Privacy Policy“) explains how Matthew Fraser LLC (“MMF,” “We,” or “Us”) collects, uses, shares, and protects information from the users of MMF’s websites and mobile or other software applications where this Privacy Policy is posted, including https://meetmattfraser.com (collectively, the “Website”). This Privacy Policy is part of the Terms of Service for the Website.  Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms of Service.

Please note that this Privacy Policy only applies to the Website, and not to websites, applications, operating systems, or other platforms of third parties, including our Event Partners (collectively, “Third-Party Websites”), even if such Third-Party Websites are linked to or accessible from the Website. Each Third-Party Website will have its own data collection and usage practices, and may use their own cookies, web beacons, and other technology to collect information from you. MMF is not responsible for the content or practices of any Third-Party Websites and, if you choose to visit or use them, you do so at your own risk.

 

1. Who controls your information?

 

Any information or other data provided to or gathered by MMF is controlled by:

Matthew Fraser LLC
P.O. Box 192
Boston, Massachusetts 02137
UNITED STATES
Marketing@MeetMattFraser.com

 

2. What types of information do we collect?

 

 

Information,” as used in this Privacy Policy, means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Website user or household. Examples include a user’s name, mailing address, email address, or IP address.

MMF collects and/or has collected over the past twelve (12) months the following categories of information about you and other users of the Website:

  • Information You Provide to Us. We collect information from you when you voluntarily provide it to us over the Website, including as part of registering, managing your User Account, and related settings. Such information may include your username, password, email address, account settings, and so forth.
  • Content You Make Public. MMF collects information from you that you voluntarily upload to the Website for public display (“Public Information”), such as when you post a comment or review or populate your public-facing profile with personal information. Once you create, post or share Public Information, neither you nor MMF are able to control how it may be copied, shared, or used by third parties, even if you and/or MMF later delete such Public Information. Accordingly, you should carefully consider what personal information you choose to include within your Public Information.
  • Transaction and Payment Information. We may gather additional information from you when you order Tickets, a Private Reading, or another product or service through the Website or contact customer service regarding a prior transaction. Such information may include your bank account number, credit card number, debit card number, or any other financial information, as well as information regarding the products or services you purchased. When you click on product links or place items in your shopping cart, we may collect or create records regarding your shopping preferences or other purchasing or consumption history or tendencies. Please note, however, that all payments are processed by third-party vendors, and not MMF itself. If you make a purchase on the Website, your payment information is sent directly to our payment processors using PCI Compliant rules/software and is never stored or otherwise retained by MMF.
  • Device/Internet Connection Information. When you use the Website, we automatically gather information made available by your web browser (such as Microsoft Edge or Google Chrome), internet service provider (such as Comcast or Cox), and device (such as your computer, phone, or tablet, depending on your settings for each). For example, we may collect your IP address, information about the operating system or type of device you use, the device ID associated with your device, the date and time you access the Website, and your log-in attempts.
  • Internet Activity Information. As explained below in Sections 3 and 4 regarding Personalized Ads, we may also collect information about your browsing history, search history, and information regarding your interaction with a particular website, application, or advertisement, including the Website. We may collect information regarding the websites, applications, or advertisements you visited immediately before and after your use of the Website.
  • Geolocation Information. We may collect information about where you are located, both generally and at the time you access the Website. For example, we may collect your mailing address or ascertain your approximate location from your IP address.
  • Other Information. From time to time, we may collect other information from you, such as when you voluntarily subscribe to promotions, push notifications, reminders, or newsletters. You will always be asked for your consent in advance of providing such other information, and we will not collect it without your permission. For the most part, you can stop providing such other information to MMF by adjusting your User Account settings.

3. How and when do we collect information about you?

 

 

MMF gathers information about you through the following sources and means:

  • When you post, enter or upload Content or other information to the Website. MMF collects information you provide to us, Public Information, Transaction and Payment Information, and geolocation information when you enter such information on the Website, sign up for newsletters or promotional material, enter contests, and otherwise interact with the Website.
  • When you attend Events. MMF collects information you provide to us, Public Information, and Transaction and Payment Information, and Geolocation Information when you purchase Tickets for and/or access, attend, and/or participate in any Event, whether a Private Reading, Online Event, or Live Event. As discussed fully in Section 7 of the Terms of Service, Events may be recorded by either MMF or its Event Partners, and your Personal Attributes may be captured within the Event Recordings.
  • When you communicate with us. MMF may also collect information you provide to us, Public Information, Transaction and Payment Information, and geolocation information from you outside of the Website, such as when you email us (including any response to an email communication from MMF) or communicate with MMF via social media.
  • Through Cookies, tracking tools, and other automated technologies. When you use any website, certain information can be automatically collected through technological means. When you access the Website, your web browser automatically sends us device and internet connection information and certain internet activity information as described in Section 2.
    MMF also uses Cookies and web beacon technology to gather device and internet connection information, internet activity information, geolocation information, and biometric information. “Cookies” are files that are placed on your computer or other device by websites you visit. The primary purpose of a Cookie is to identify you as a unique User of the Website. MMF uses the following types of Cookies, some of which are placed by Third Parties, to customize your Internet experience, keep you logged into websites, remember your search terms, and advertise products or services to you:
Type of Cookie Purpose of Cookie
Necessary

Necessary Cookies are essential in order for the Website to display and perform properly. Necessary Cookies are used to identify you, prevent security risks, and to allow you to perform account-related functions.

MMF uses the following Necessary Cookies on the Website:

· Session – a Cookie set for logged-in Users which allows the server to remember that you are logged in.

· Consent – a Cookie set to record and remember any consents you have already provided to MMF (such as a Cookie consent for Users in the EU or UK) so that you are not prompted for additional consent each time you visit the Website.

· Third-Party Security – these Cookies are set by our third-party service providers to help secure your User Account and the Website.

Preferences Preferences Cookies are used to store preferences set by you and each user for their account, such as your language preferences. Preferences Cookies improve your experience using the Website.
Analytics and Performance Analytics and Performance Cookies collect information on how you and other users interact with the Website. Often, this information is aggregated, as discussed in Section 4, and is used to improve the Website.
Advertising We may also use Cookies and web beacons, including those placed by Third Parties such as Google and Facebook, to deliver Personalized Ads that may be of interest to you. We may also use a web beacon in email messages sent to track your response. Cookies and web beacons also help us, and our Third-Party advertising partners ensure you do not see the same advertisements over and over and to identify and block unwanted ads.
  • You can change your Cookie settings in your Internet browser (e.g., Chrome, Edge, Firefox).  If you disable Cookies, some of the features of the Website may not function correctly. For more information, see https://www.allaboutcookies.org/.
  • From Third Parties. MMF may also collect the following types of information from Third Parties: device/internet connection information; internet activity information; and geolocation information.Like many websites, MMF uses Google services and Cookies to improve the Website and advertise to users like you, as described more fully below.  As such, when you use the Website, your personal information may be shared with Google, and shared by Google with MMF. You can learn more about how Google uses Cookies, and how to manage your Cookie preferences in your Internet browser and revoke your consent to Personalized Ads, by visiting the Google Cookie Policy.MMF may also use the Facebook Cookie to deliver Personalized Ads to you, as that term is described below. You can learn more about how Facebook gathers and uses personal information via Cookies, including how to set your Cookie preferences within Facebook, by visiting the Facebook Cookie Policy.

    You can better learn about such Third-Party data collection and advertising practices, including how to revoke your consent to Personalized Ads, at the following websites:
    www.youronlinechoices.com/uk/your-ad-choices
    www.networkadvertising.org/choices
    www.aboutads.info/choices

4. How do we use your information?

 

 

MMF may use the information we’ve gathered from you or your device, including through Cookies and Third Parties, for the following purposes:

  • Business Purposes. When MMF uses your information for a “Business Purpose,” it means such use is reasonably necessary and proportionate to achieve an operational purpose of MMF. The following are the Business Purposes for which we may use your information:
Business Purpose Types of Information

 

For Security. MMF uses the information we collect from you and other users to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and prosecute those responsible for that activity.

 

 

Information you provide to us; Device/Internet Connection Information; Public Information; Transaction and Payment Information; Internet Activity Information; Geolocation Information

 

To Improve the Website. MMF uses the information we collect from you and other users to provide and improve the Website. We use information to debug and identify and repair errors that impair existing intended functionality of the Website. As explained above, we use Cookies, including those placed by Third Parties, to gather statistical information that helps us understand how you and other users engage with the Website and improve its performance via technological development.

 

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

To Personalize Your User Experience. We use information gathered from Cookies to make it so you don’t have to reenter the same information when you visit the Website several times within a short timeframe.

 

Information you provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information

 

To Communicate with You. We use your information to personalize communication with you.

 

Information you provide to us; Public Information

To Create Deidentified Aggregate Information. MMF may combine your information with that of other users to create “Aggregate Information”—namely, statistical information about all users or a subset thereof. Aggregate Information is pseudonymized and deidentified. In other words, Aggregate Information cannot be used to identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular User, including you.

 

In turn, Aggregate Information may be used by MMF for the Business and Commercial Purposes listed herein.

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

 

 

  • Commercial Purposes. When MMF uses your information for a “Commercial Purpose,” it means such use is intended to advance MMF’s business interests, such as to sell you Tickets. The following are the Commercial Purposes for which we may use your information:
Commercial Purpose Types of Information

 

To Advertise to You. We may use information gathered through Cookies and web beacons, including those placed by Third Parties, to deliver ads to you via the Website, and after you’ve left the Website, including advertising specific to your personal interests. The purpose of this practice, which is sometimes called “Personalized Ads,” “retargeting,” or “remarketing” is to deliver content and advertising that is of interest to you, and to avoid displaying irrelevant advertising to you.

 

 

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

To Advertise to Others. We may share your reviews, comments, and other content uploaded by you to advertise and market our Website and the Services, including by reposting your reviews on the Website, in our advertising, or through our social media accounts. Public Information

 

  • Scope and Legal Bases for Use

MMF only processes your information to the extent that is necessary to accomplish the above-stated Business and Commercial Purposes, which serves as our legitimate interest.

If you reside in a location governed by the GDPR, then the following are MMF’s legal bases for the processing of your information: In so far as we have obtained consent for processing operations of information by the data subject, Art. 6(1) lit. a GDPR serves as the legal basis. For the processing of information necessary for the performance of a contract to which the data subject is a party, Art. 6(1) lit. b GDPR serves as legal basis. The same applies to such processing operations which are necessary for carrying out pre-contractual measures. In so far as the processing of information is required to comply with a legal obligation to which MMF is subject, Art. 6(1) lit. c GDPR serves as legal basis. In the event that processing of information may be necessary to protect the vital interests of the data subject or of another natural person, Art. 6(1) lit. d GDPR serves as legal basis. If processing is necessary for the purposes of the legitimate interests pursued by our MMF or by a Third Party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, processing operations are based on Art. 6(1) lit. f GDPR.

 

5. How do we share your information?

 

 

MMF may share your information with Third Parties for the following purposes:

  • Business Purposes. When MMF shares your information for a Business Purpose, it means such use is reasonably necessary and proportionate to achieve an operational purpose of MMF. The following are the Business Purposes for which we may share your information:
Third Parties Business Purpose Types of Information

 

Service Providers. These Third Parties provide services to MMF that allow MMF to operate the Website. Examples include email fulfillment providers and so forth.

 

For Security; to Improve the Website, to Personalize Your User Experience; and to Create Aggregate Information.  See Section 4 for more information on these Business Purposes.

 

 

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

Our Affiliated Entities. Affiliated entities are different than Third Parties in that they are businesses that are directly related to us and have common ownership with us. We may disclose, transfer, and sell your information to our affiliated entities, in which event, your information shall be treated by the affiliated companies in accordance with this Privacy Policy. Should MMF be subject to an acquisition, merger, sale or other change of control or business entity status, we reserve the right to transfer or assign your information as part of that acquisition, merger or sale.

 

 

For Security; to Improve the Website, to Personalize Your User Experience; and to Create Aggregate Information.  See Section 4 for more information on these Business Purposes.

 

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

 

Government Officials and Private Parties Pursuant to Valid Legal Process. We may disclose your information in response to subpoenas, court orders, and other legal processes. In very rare circumstances, we may disclose personal information when we believe it is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.

 

To comply with MMF’s legal obligations and to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.

 

Information you provide to us; Public Information; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

 

 

  • Commercial Purposes. When MMF shares your information for a “Commercial Purpose,” it means such disclosure is intended to advance MMF’s business interests, such as by advertising our products or services. The following are the Commercial Purposes for which we may share your information with Third Parties:
  Commercial Purpose Types of Information

 

Advertising Partners. We may disclose your personal information as needed to our Third-Party advertising partners.  For example, when you click on an affiliate link on the Website, the listed types of personal information may be passed to the vendor so that we earn commission on any purchase you make on the vendor’s site.

 

 

To Advertise to You, including through Personalized Ads; to Advertise to Others. See Section 4 for more information on these Commercial Purposes.

 

 

 

Information you provide to us; Public Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information

Other Consumers. We may share your reviews, comments, and other content uploaded by you to advertise and market our Website, including by reposting your reviews on the Website, in our advertising, or through our social media accounts. To Advertise to Others. See Section 4 for more information on this Commercial Purpose. Public Information

 

6.  Do we sell your information to others?

 

 

No. MMF does not sell consumers’ personal information and has not sold consumers’ personal information during the past twelve (12) months.

 

7.  How do we protect your information?

 

 

MMF, and the Third-Party vendors we use to store your information, employ technical, administrative, and physical security measures (such as SSL encryption and HTTPS protocol) that are designed to protect against the loss, misuse, and alteration of the information under our control. We regularly review our security procedures to consider appropriate new technology and methods.

However, no system can be completely secure.  Therefore, although we take steps to secure your information, we cannot promise, and you should not expect, that your personal and commercial information, or other communications, will always remain secure.

The safety and security of your information also depends on you. Never share your password with anyone else and notify us as soon as possible if you believe your account security has been breached.

 

8. How long do we keep your information?

 

 

MMF will retain your information for the length of time necessary to fulfill the Business Purposes and Commercial Purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law or valid court order. If you request deletion of your information pursuant to Section 10, your request will be processed according to the timeframes in any applicable legislation.

 

9. Do we transfer your information to a different country?

 

 

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Website, you authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified above when you provide such information to us.

 

10. What are your rights when it comes to accessing, correcting, or deleting your information, and how can you exercise them?

 

 

You may access all information we’ve collected and retained about you for purposes of correcting, amending, downloading, or deleting such information. Your rights may depend upon the laws of your jurisdiction of residence. Your rights can be exercised by contacting us at Marketing@MeetMattFraser.com or by visiting our Contact Us page to make your Privacy Request.

To protect your privacy and security, we may take reasonable steps to help verify your identity and jurisdiction of residence before granting access, making corrections, providing you with information, or deleting information.

  • Access and Correction
    You may have the right to access and correct the personal information we have collected about you.
  • Right to Request Disclosure
    You may have the right to request that MMF disclose the following to you:
    • The categories of personal information we have collected about you;
    • The categories of sources from which the personal information was collected;
    • The business or commercial purpose for collecting or selling personal information;
    • The categories of third parties with whom we share personal information; and
    • The specific pieces of personal information we have collected about you.
  • Right to Request Deletion
    You may have the right to request that MMF delete certain personal information about you which we have collected from you.
  • California Shine the Light Disclosure
    Under California’s “Shine the Light” law, California residents who provide personal information to the Website may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

11. How do we protect the privacy of children?

 

 

  • No Users Under 13
    MMF will never knowingly collect any personal information from children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to Third Parties. We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
  • Bus. & Prof. Code § 22581 Disclosure
    If you are a California resident under the age of 18, and a registered user of any Website where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of Content or information you have publicly posted.

12. How can you receive and opt-out from marketing communications?

 

 

At the time you create your User Account, you will be given the opportunity to opt-in to receive email, push, browser and/or other electronic communications from MMF. You may change your communications preferences at any time through your User Account settings; provided, however, that even if you opt-out of all electronic communications and notifications, MMF will still be authorized to email you about updates to this Agreement or Privacy Policy, reports or complaints submitted by or about your User Account, your breach of this Agreement and/or other administrative matters concerning your User Account.

 

13. Do we respond to Do Not Track (“DNT”) Signals?

 

 

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked.  MMF does not currently respond to DNT requests.

Note that DNT is for web browsers and is different than Authorization to Track (“ATT”) authorization for mobile applications. ATT permissions are controlled by your mobile phone or other device’s operating systems.

 

14. How will you know when we change the Privacy Policy?

 

 

Each time you use the Website, the then-current version of this Privacy Policy will apply.  Although most changes are likely to be minor, we reserve the right to modify this Privacy Policy by posting such modification on this page; however, if changes are significant, we may provide a more prominent notice or email you. Depending upon your location, we may obtain additional consent from you via a checkbox disclosure or an email requesting consent before you can continue to use the Website.

Unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier version.

 

15. How can you contact us regarding this Privacy Policy?

 

 

You can contact us via email at Marketing@MeetMattFraser.com

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