Last Updated: May 28, 2020
This privacy notice (the “Privacy Notice”) is for Mylo, a service operated by CDS Global, Inc. (“CDS”, “we”, “our” or “us”). Mylo is a digital authentication service (single sign-on) (the “Services”) that enables users to (a) sign in to websites, apps and other digital properties operated by various publishers and other operators (collectively, the “Participating Properties”) and (b) interact with various features offered on the Participating Properties, such as purchasing subscriptions, signing up for newsletters, participating in surveys, sweepstakes, polls or contests and commenting on articles.
This Privacy Notice does not describe the data handling practices of the Participating Properties. We encourage you to review the privacy notices and similar statements of the operators of such Participating Properties to learn about their privacy practices, including about the cookies and similar technologies they may use.
A. What Information We Obtain
When you use the Services, we obtain various types of information about you and your use of the Services. This includes information that directly identifies you such as your name and email address (this type of information may be called “personal information” or “personally identifiable information”). The information we obtain generally consists of information (1) required for your Mylo user account registration and authentication, (2) about your transactions and activities on the Participating Properties or use of the Services; (3) about your friends and contacts; (4) from third-party sources; and (5) collected through automated means such as cookies.
In addition, we de-identify and/or aggregate the information we obtain about you and others (the “De-identified Data”). The requirements and limitations described in this Privacy Notice on our collection, use, sharing, disclosure, transfer and retention of information do not apply to such De-identified Data as well as information that cannot be used to identify you.
We obtain information about you when you use the Services or interact with Participating Properties, including the following:
1. Information Required for Your Mylo User Account Registration and Authentication
To use the Services, you will need to create a user account that will allow you to sign in on a variety of Participating Properties. We ask you to provide certain personal information, including your name, email address and password or other identification information required to establish your account and authenticate your access to the Services and Participating Properties. These are the “credentials” that we will use to authenticate you. We may require you to provide additional personal information as you use our Services. We assign a unique ID number to your credentials to track your use of the Services and associated information. If you register for Mylo using your Facebook, Google or other social media login, we obtain your information from the relevant social media login provider and such provider also may collect information about your activities related to the Services and Participating Properties.
2. Information About Your Transactions and Activities
When you use our Services on Participating Properties and make transactions or engage with certain features provided on the Participating Properties, for example, by buying a subscription or signing up to a newsletter, we obtain information about your transaction (collectively, the “Interactions”). The categories of information collected vary depending on your Interactions and each Participating Property and may include:
- Subscriptions, Orders and Purchases Information. If you choose to sign up to a newsletter, purchase a subscription or order a product, enroll in a rewards program, we may obtain information such as your name, email address, postal address, telephone number, payment and billing information and order information.
- Surveys, Sweepstakes and Similar Features. If you participate in surveys, polls, sweepstakes, contests, promotions and similar features on Participating Properties, we may obtain information about your participation as well as your answers or other user generated content you choose to submit as part of your participation. This may also include information about your participation in activities that may generate loyalty or rewards points.
- Information Derived from your Interactions with the Services or Participating Properties. When you use the Services or visit Participating Properties, we collect information about your Interactions to derive inferences about your interests and preferences and we may assign interests and preferences to you based on your Interactions. Some of this information may be automatically collected through Automated Means.
3. Information About Your Friends and Contacts
As part of your use of the Services or Interactions with the Participating Properties, you may choose to provide information about others. Do not provide information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Notice.
4. Information From Participating Properties and Third-Party Sources
When you use the Services to access the Participating Properties, the relevant publishers and other operators of such Participating Properties may share information about you and your Interactions with us. In addition, we may obtain information about you from data suppliers, social media platforms and others. We may combine any of the information we obtain about you, including information obtained from the Participating Properties, with information we obtain offline and from third-party sources. For example, we may obtain data from:
- Data suppliers such as data aggregators, data resellers, public databases and business partners. They may provide us with demographic information and other information about you.
- Social Media Platforms and similar services (“Social Media Platforms”). When you engage with content or ads on Social Media Platforms, or interact with features on the Participating Properties that contain content or features provided by Social Media Platforms (e.g., log in or sign in features or tools that allow you to share our content with others on Social Media Platforms), we may obtain information from Social Media Platforms, including your username, user ID, demographic information and other information, subject to the settings and privacy practices of the relevant Social Media Platform. We may obtain this information directly from the Social Media Platform or through plug-ins, integrations or other applications. Please keep in mind that the operators of the Social Media Platforms may also gather information about your use of the Participating Properties and their features and tools. To limit the information we receive from Social Media Platforms, please check with the Social Media Platform(s) you use to learn how you can limit their ability to share your information with other parties.
5. Information Collected Through Automated Means
The Services automatically log certain information about your use of the Services and visits to the Participating Properties, such as the number and frequency of visitors, technical information about browsers and devices used to access the Services and Participating Properties, and information about technical issues regarding the use of the Services or Participating Properties. In addition, we and third parties may automatically collect certain information through automated means about your activities over time across the Participating Properties as well as across other third-party sites or media (i.e., your devices). The tools that collect this information vary depending on the Participating Properties and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits (collectively, “Automated Means”). These Automated Means may be included in our web pages, mobile apps, emails, and other digital content. The Automated Means may assign or collect unique cookie IDs or other identifiers associated with your browser or device. The Automated Means may collect information while you are using the Services, while you are visiting Participating Properties or while they are running in the background of your device.
The information collected through Automated Means may include:
- Information about your computer, device, browser and operating system (e.g., type, model, or version);
- Internet protocol (IP) address, which may be used to derive your general geographic area (e.g., city and country);
- Device identifiers (e.g., mobile advertising IDs);
- Information about your interactions with the Services and Participating Properties, including browsing activities and clickstream data that reflect the content you have accessed, clicked on, purchased or viewed;
- Information about how you accessed the Services and Participating Properties, including details about websites or apps visited immediately before or after accessing the Services and Participating Properties; and
- Demographic, interests and household information.
For more information about the use of Automated Means in the context of interest-based advertising and how you can limit tracking, see here.
B. How We Use Information We Obtain
If you make a purchase or place an order through or in connection with your use of the Services and such payment transaction is processed by us, we use your payment information (e.g., your card number and expiration date) for limited purposes such as to process your transaction (including recurring payments, if applicable), to provide you with the requested products or Services and for the purposes described under the section “To protect our rights or the rights of others” below.
With respect to information other than your payment card information, we use that information:
1. To Provide You With the Services, Including Improving and Tailoring Your User Experience on the Participating Properties. This includes:
- Authenticating and enabling you to access the Participating Properties;
- Facilitating your Interactions on the Participating Properties and helping you manage your preferences;
- Providing customer assistance or technical support for the Services;
- Delivering customized product recommendations and other content and enhancing the quality and your overall experience with the Services and/or Participating Properties, including by retaining your user preferences or presenting content in the most effective manner for the browser or device you use to access the Services and Participating Properties;
- Maintaining, operating, improving and developing the Services, Participating Properties and related content, products or services, including developing new products and features based on users' interactions with the Services and Participating Properties; and
- Learning about users of the Services and analyzing how you and others interact with and respond to the Services and Participating Properties, including by measuring and optimizing usage, reliability and performance, conducting market research, analyzing trends, and supporting our operations (e.g., for accounting, auditing, financial, legal or other purposes).
2. To Communicate With You. This includes:
- Sending you informational messages about the Services (e.g., to confirm your account registration, reset your password or notify you of changes to the Services);
- Delivering marketing or promotional communications by email or other channels, including offers or promotions about the Services and Participating Properties or third parties' products, services or other initiatives; and
- Responding to your questions or addressing your requests regarding the Services.
3. For Advertising and Marketing Purposes, Including Interest-Based Advertising. This includes:
- Developing, managing and conducting advertising and marketing campaigns, promotions and offers, including about Participating Properties' content, products and Services or third parties' products, services and other initiatives;
- Interest-based advertising (also known as targeted or personalized advertising or ads) is advertising based on your interests as inferred from your activities over time on the Services and Participating Properties, and online services operated by third parties, as well as information from other sources, including information collected offline. Interest-based ads may consist of text ads, images, animations or videos and may be displayed to you based on various factors, including the context of the site or app in which they appear (e.g., sport or travel section), information you provided to the operator of the site or app, your activities on the sites or app (e.g., pages viewed, searches performed or ads clicked), and information such as your demographic, interests and household information:
- On the Participating Properties and on third-party sites, apps or other media, we, our service providers and third parties may use Automated Means to (a) collect information for interest-based advertising purposes or (b) serve you interest-based ads. These Automated Means vary depending on the Participating Properties and sites visited. These Automated Means may use unique identifiers associated with your browser or device to support interest-based advertising.
- We may use and/or combine online and offline information we obtain about you, including your personal information, for interest-based advertising purposes. We may aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.
- Interest-based ads may be displayed to you by third parties, such as ad networks or exchanges.
- There are steps you can take to limit the collection of your information for interest-based advertising purposes. These steps vary for the web and mobile app environments and are browser and device specific. To learn more about interest-based advertising and opt-out choices, see https://optout.aboutads.info and here.
- In serving interest-based ads, we adhere to the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance.
- Cross-device linking. If you access the Services and Participating Properties from multiple browsers or devices, we, our service providers and third parties may try to establish connections among and link the different browsers and devices you use to access the Services and Participating Properties, and content or ads published elsewhere. This helps us and others provide you with a seamless experience across the browsers and devices you use and serve you with more relevant content and ads (e.g., so that we don't show you the same article twice). See here for steps you can take to limit browser and mobile app tracking for interest-based advertising purposes; and
- Analyzing and measuring the performance, effectiveness and reach of our or the Participating Properties’ advertising (including interest-based ads) and marketing efforts on the Participating Properties and elsewhere.
4. To Protect Our Rights or The Rights of Others. This includes:
- Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Services or Participating Properties, intellectual property infringement or other violations of law, this Privacy Notice, our Terms of Service or other applicable policies;
- Performing audits, assessments and testing or troubleshooting activities;
- Backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Services or Participating Properties; and/or
- Complying with and enforcing applicable industry and legal requirements (including legal process such as court orders, warrants or subpoenas) and fulfilling contractual obligations.
C. How We Share Information
We may share the information we obtain with:
- Affiliates and Subsidiaries. CDS Global, Inc. is a member of the Hearst family of companies. We work closely with affiliates and subsidiaries within the Hearst family of companies with whom we share your information as necessary or appropriate to operate the Services and facilitate access to the Participating Properties.
- Participating Properties and Business Partners. We provide your information to the publishers and other operators of the Participating Properties we partner with to provide the Services and facilitate your Interactions with the Participating Properties. This includes enabling you to sign in to multiple brands across one or several publishers and other operators of Participating Properties using a single set of sign-in credentials, which allows us to show you in your Mylo account information about your Interactions across the Participating Properties on which you used the Services. We may also provide your information to business partners as well as other joint marketing partners and content sponsors with which we partner to provide the Services for various purposes. For example, we may partner with a third party to offer products on a co-branded, co-sponsored or cross-promotional basis that involves the sharing of information. These initiatives may be offered on the Services, Participating Properties or on other media.
- Service Providers. In connection with the operation and provision of the Services, we engage various third parties to provide services or handle transactions on our behalf, such as payment card processing, email distribution, list processing, postal mailing or other courier services we engage for product delivery, cloud computing, analytics, , promotions or events. These service providers use the information we provide to them as necessary or appropriate for the performance of their services. The Participating Properties may also use service providers to make available certain features or process your Interactions and are responsible for the sharing of your personal information with the service providers they use.
- Advertisers, Advertising- and Marketing-Related Service Providers and Partners. We may provide your information to advertisers, advertising agencies, ad networks, ad exchanges, marketing businesses, technology vendors and other entities that create, deliver and assess advertising or marketing campaigns, including interest-based ads.
- Social Media Platforms If you create your Mylo account by linking your Facebook, Google or other social media account or otherwise interact with social media widgets, share content using social media share buttons, or access features of the Services and/or Participating Properties that contain content or features provided by Social Media Platforms, the relevant Social Media Platforms may collect information about you or your activities. We encourage you to review the privacy policies of the Social Media Platforms that you engage with as we are not responsible for their privacy practices.
- Other Parties When Required by Law or As Necessary to Protect Our Rights. We may share your information as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Services and Participating Properties or other individuals and entities, or to comply with or enforce applicable industry standards, law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.
- Corporate Transactions. We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition or in connection with a bankruptcy reorganization, dissolution or liquidation.
- With Your Consent or Otherwise at Your Direction. In addition, we may share your information with third parties when you consent to or request such sharing.
D. Your Choices
Direct Marketing Opt-Outs
Email marketing. You may opt out of receiving marketing or promotional emails from the Participating Properties by clicking on the “unsubscribe” link contained in emails they sent or following other instructions they provide. Please keep in mind that if you opt out of receiving marketing or promotional emails, we or the relevant Participating Property may still send you transactional emails or other communications relating to your use of the Services (e.g., to confirm your account registration, to inform you of changes to the Services or in response to your password recovery request) or Participating Property.
Interest-Based Ads Opt-Outs
Some of the ads you see on the Participating Properties are interest-based ads. This means that these ads are customized based on the information the operators of the Participating Properties and others obtain about you. We describe below steps you can take to limit tracking of your activities and the delivery of interest-based ads in browsers and mobile apps you use to access the sites or apps. Please keep in mind that if you opt out of interest-based ads, you will still see ads, but these ads will not be based on your inferred interests. In addition, if you take the steps described below, some Automated Means may still be used to collect information about your interactions with the Services for the other purposes described in this Privacy Notice (e.g., to remember user preferences or enable specific functionality) and purposes described in the privacy notices of the relevant Participating Properties.
The technologies used to deliver ads on websites and mobile apps differ. Please also remember that opt-outs are browser- and device-specific.
Website (Browser) Opt-Out
- Disabling Cookies. Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies.
- Opt-out Cookies. You can follow the instructions provided by the Digital Advertising Alliance (“DAA”) here and/or the Network Advertising Initiative (“NAI”) here to place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser.
- If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt-out choices for that specific browser.
- The opt-out mechanisms offered by the DAA and NAI are provided by third parties. CDS does not control or operate these mechanisms or the choices provided through these mechanisms.
- To opt out of Google Analytics on your browser or device, please visit here and follow the instructions.
Mobile App Opt-Out
- Device Settings. To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as "Limit Ad Tracking” for iOS or "Opt-out of interest-based ads” for Android.
- AppChoices Application. AppChoices Application. You can download the “AppChoices” application provided by the DAA from your app store. AppChoices offers a mechanism to limit the collection of app data used for interest-based ads by participating companies. See here for more.
Please keep in mind that as the mobile environment continues to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that device manufacturers, technology companies and industry associations make available to you.
- User account. If you have created an account to use the Services, you may be able to review some of your information for that account by signing in and updating your information or user preferences.
- Device Settings. You may be able to review and adjust your preferences by updating the settings on your device (e.g., permitting us to collect precise location information).
- Push Notifications. If the Services enables push notifications on your browser or device, you may review and update your push notification preferences by adjusting the settings on your browser or device. For example, you can select the relevant app from “Notifications” (for iOS devices) or “App notifications” (for Android devices) and turn off alerts accordingly.
E. Do Not Track
We do not currently take steps to respond to browsers' “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.
F. How We Protect Your Information
We use a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
G. Non-U.S. Visitors
We operate the Services from the United States. Any information we obtain about you in connection with your use of the Services may be processed and stored in the United States or other countries.
H. Children’s Privacy Rights
The Services are not intended for use by children, especially those under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us as indicated below.
I. Links to Third-Party Websites, Mobile Apps or Other Services
The Services and Participating Properties may contain links to websites, mobile apps or other services operated by companies not affiliated with CDS. In addition, the Services may be made available to you through third-party platforms (such as app stores or Social Media Platforms) or other channels. We are not responsible for the privacy practices of any third-party operated websites, mobile apps or other services and channels, including publishers and other operators of the Participating Properties, and we encourage you to review the privacy policies or notices published by relevant third parties.
J. Dispute Resolution/Terms of Service
Any dispute concerning the Services (including our use of your personal information) will be resolved per the dispute resolution provision in the Terms of Service, which govern your use of the Services. Please take a few minutes to read the Terms of Service before using the Services.
K. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the relevant Services and indicate at the top of the Privacy Notice when it was most recently updated. Your use of the Services will be governed by the then-current version of the Privacy Notice.
If you have any questions about this Privacy Notice, please contact us by email at email@example.com.
M. Additional Information for California Residents
Under California law, specific disclosures are required and California residents have additional rights regarding their personal information. Please review this section to learn more.
Your California Consumer Privacy Act of 2018 (“CCPA”) Rights
Residents of California may have the following rights:
- Right to access your personal information. You may request to access the categories and specific pieces of personal information that we collected about you through Mylo.
- Right to deletion. Subject to certain exceptions, you may ask us to delete the personal information we collected about you through Mylo.
- Right to disclosure. You may request to receive additional details about the sources from which we collect information, the reasons we collect and share information, and the types of third parties with which we share the personal information we collected about you through Mylo.
- Right to opt out of sales. Under CCPA, certain types of sharing of personal information may constitute a “sale” of your personal information. When you engage with the Services and CDS shares your personal information with the relevant Participating Property, you direct CDS to share your information with the relevant Participating Property with whom you choose to interact by using our Services. This type of interaction does not constitute a “sale” of your personal information by CDS.
- Right to be free from discrimination. You may exercise any of the above rights without fear of being denied goods or services.
If you would like to exercise your CCPA rights with respect to the personal information we collected about you through Mylo (the Services), please contact us by email at firstname.lastname@example.org and please indicate “CCPA Request” in the subject line and the right(s) you would like to exercise.
Please note that you will need to contact directly the publishers and other operators of the Participating Properties with whom you have interacted using the Services to exercise your California privacy rights with respect to the personal information they maintain about you, including information collected through cookies and similar technologies, and exercise your right to opt out of sale of your personal information.
We do not knowingly collect or disclose personal information of minors under the age of 16, without affirmative authorization.
Your Shine the Light California Rights (CA Civil Code § 1798.83)
Residents of California may request a list of third parties to which certain personal information (as defined by applicable California law) obtained through the Services was disclosed by CDS during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at Office of General Counsel, Attn: Privacy, 300 West 57th Street, New York, NY 10019. For such requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. Please also indicate in your request that it relates to Mylo. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
N. Additional Information for European Users
In order to address our legal obligations in Europe (including the UK), CDS provides the following additional information for Europe-based users of the Services.
Who is Responsible for Your Information?
When you use the Services, then the data controller will be CDS Global, Inc. The contact details for this entity are provided in the “Contact Us” section above.
In addition, the publisher or other operator of a Participating Property on which you may use the Services will be the data controller with respect to the personal data collected and used on such Participating Property. We encourage you to review the privacy notice or similar statement published on each Participating Property to find out more about the relevant data controller, including their contact details.
Legal Bases for Using Your Information
We process personal information for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases:
- To perform our contractual obligations to you. We and our service providers process your information to perform our contractual obligations to you when we use your information to provide you with the Services and related content, products or services and to communicate with you. For example, when you purchase a subscription via the Services, we process your payment and contact information as necessary to confirm the subscription and we process your contact information and other details to provide you with support services you request. We also send you informational communications on this basis, including to confirm a subscription or to notify you of a change to the Services. Failure to provide requested information could prevent or delay the fulfillment of our contractual obligations.
- To pursue our legitimate interests. We process your information to meet our legitimate interests when we use your information to provide you with the Services and related content, products or services, to communicate with you and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Services and related content, products or services, and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries, service providers and business partners (including for our advertising and marketing purposes) and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
- To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. For example, we are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons.
- With your consent. We obtain your consent to process your information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the “Contact Us” section above.
Your Rights Over Your Information
In certain circumstances, you have a right to access or object to the use of personal information held about you (including in relation to direct marketing). You can also ask us to rectify, update, erase, restrict or to share your information in a usable format with another company. Such requests are subject to applicable law. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. If you would like to discuss or exercise such rights, please contact us at email@example.com. We will contact you if we need additional information from you in order to honor your requests.
Storing Your Information
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
- Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Services.
- Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
- Defend, establish, exercise or bring any existing or potential legal claims.
- Carry out fraud detection and prevention.
- Deal with any complaints regarding the Services, our products and services.
International Data Transfers
Information collected through the Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. If we transfer personal data from the European Economic Area, United Kingdom and Switzerland we put in place safeguards.
Changes to the Privacy Notice
Where changes to this Privacy Notice have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you advanced notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
Privacy Officer and Complaints
We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.