1.     Introduction and Overview.

This Privacy Policy provides a comprehensive description of how Lewis Media Partners, LLC (“Lewis Media Partners,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your rights and choices regarding such information. It applies to any online location controlled by us that links to this Privacy Policy (the “Service”). 

This Privacy Policy does not govern information we process on behalf of our clients. For details about the processing of client data, please see the “Information from Our Clients” section below.

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. 

You may have additional rights based on your jurisdiction. Please click the relevant link below for more information:

• California
• Nevada
• Virginia

2.     Information Collection.

A.     Information You Provide.

We collect information about you when you use the Service, including information you provide when you access our content, contact us, or apply for a job. The categories of information we collect include:

• Contact Data, including your email address.
• ‍Content, including content within any messages you send to us (such as feedback or questions to customer support) 
• Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions. 

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.  

B.     Information Collected Automatically.

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id (which is a user-resettable identifier associated with your device). 
• Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level.

The types of tracking technologies we use to automatically collect this information include:

• Cookies, which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and expire on a set expiration date or when they are deleted manually. 
• Pixels (also known as web beacons), which is code embedded in a service that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser, or collect other information about your visit. 
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C.     Information From Our Clients.

We provide products and services to our clients, and collect and process information about individuals (including through tracking technologies) at the direction of our clients (“client data”). Client data has historically included contact data, demographic data, content, service use data, device data, and location data, among other information. Our processing of client data is governed by the terms of our service agreements with our clients, and not this Privacy Policy. In the event we are permitted to process client data for our own purposes, we will process the client data in accordance with the practices described in this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies. 

For further information on your rights and choices regarding client data, see the “Your Rights and Choices” section below.

D. Information From Other Sources.

We also collect information from other sources. The categories of sources from which we collect information include: 

• Social media platforms with which you interact.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly-available sources, including data in the public domain.
• ‍Data Brokers from which we purchase or license data to supplement the data we collect. 

3.     Use of Information.

We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

• Providing the Service to you.
• Preventing and addressing fraud, breach of policies or terms, or threats or harm. 
• Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.
• Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
• Personalizing your experience to show you content we believe you will find interesting. 
• Engaging in direct marketing, promotional communications, and non-personalized advertising. 
• Engaging in personalized advertising, including Interest-based Advertising.
• Fulfilling any purpose at your direction.
• With notice to you and your consent.

Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4.     Disclosure of Information.

We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include: 

• Service Providers and Contractors. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.
• Analytics and Advertising. We disclose information to vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below. 
• Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Clients. We disclose information to our clients in connection with the services we provide to them. For example, we disclose information to clients in order to facilitate your orders, maintain and administer your accounts, respond to your questions, comply with your requests, market and advertise to you, and otherwise comply with the law. Our clients are independent entities and their processing of information is subject to their own privacy policies.
• Partners. We disclose information to our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities. 
• Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
• Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business. 
• Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else. 
• Facilitating Requests. We disclose information where you direct us to disclose the information. 
• Consent. We disclose information with notice to you and your consent. 

Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.

5.     Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. 

Some examples include:

• ‍Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. 
• Brand Pages and Messaging. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Lewis Media Partners in a tweet or post), we may use your reference on or in connection with our Service.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6.     Analytics and Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services. 

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7.     Your Rights and Choices

In addition to the rights and choices below, you may have additional rights based on your jurisdiction. Please click the relevant link at the top of this Privacy Policy or visit the applicable section below for more information.

A.     Tracking Technology Management.

• Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly. 

B.     Analytics and Interest-Based Advertising Management.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.  

The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver Interest-based Advertising to you, but does not mean that the participants will not process your information for Interest-based Advertising purposes or that you will no longer receive Interest-based Advertising from other companies. 

Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities. 

C.     Communications.

• E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at donotreply@lewismediapartners.comwith the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.

Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.  

8.     Children.

The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at donotreply@lewismediapartners.com. We will delete the personal information in accordance with COPPA. 

9.     Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10.     International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, disclosure, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.

11.     Changes to this Privacy Policy

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.  

12.     Contact Us.

By email:

‍donotreply@lewismediapartners.com 

By mail:

Lewis Media Partners
500 Libbie Avenue, Suite 2C
Richmond, VA  23226

13.    California.

The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.

Our Service is also intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) us conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

We acknowledge that you may have rights under the CCPA/CPRA in connection with the personal information we process on behalf of our clients. If personal information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

A.     Notice of Collection

We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.

• Identifiers, including email address and online identifiers (such as IP address).  
• Internet activity, including browsing history, search history, and interactions with a website, email, or advertisement. 
• Non-precise geolocation data, including location derived from an IP address.
• Professional, employment, or education-related information.
• Inferences drawn from any of the information identified in this section. 

We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above. 

We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above. 

We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA/CPRA. A “sale” is broadly defined under the CCPA/CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We may collect, sell, or share the following categories of personal information for commercial purposes: identifiers, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.

We do not sell your personal information as that term is traditionally understood. However, some of our disclosures We do not knowingly sell or share the personal information of minors under 16 years old who are California residents. of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA/CPRA. A “sale” is broadly defined under the CCPA/CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We may collect, sell, or share the following categories of personal information for commercial purposes: identifiers, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.

B.     Retention.

We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

C.     Right to Know, Correct, and Delete.

You have the right to know certain details about our data practices. In particular, you may request the following from us:

• The categories of personal information we have collected about you;  
• The categories of sources from which the personal information was collected; 
• The categories of personal information about you we disclosed for a business purpose or sold or shared; 
• The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared; 
• The business or commercial purpose for collecting or selling or sharing the personal information; and 
• The specific pieces of personal information we have collected about you.

Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort. 

In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you. 

To exercise any of these rights, please email us at donotreply@lewismediapartners.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request. 

D.     Right to Opt-Out

To the extent we “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA, you have the right to opt-out of the “sale” or “sharing” (effective January 1, 2023) of your personal information by us to third parties at any time. You may exercise this right through our form at Do Not Sell My Personal Information or by emailing us at donotreply@lewismediapartners.com and specifying you wish to opt-out. 

E.     Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. 

F.     Right to Non-Discrimination.

G.     Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.